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Invergordon Service Base Phase 4 Development Construction Environmental Management Document Document History Issue Date Reason for Change 1 15/05/18 Issued for Marine Licence Application

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Page 1: Invergordon Service Base Phase 4 Development … › ... › CEMDPhase4PoCF.pdfInvergordon Service Base Phase 4 Development Construction Environmental Management Document Document

Invergordon Service Base Phase 4 Development

Construction Environmental Management Document

Document History

Issue Date Reason for Change

1 15/05/18 Issued for Marine Licence Application

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Contents:

• Section 1: Introduction

• Section 2: Background

• Section 3: Roles and Responsibilities

o Appendix 3A: Personnel List

• Section 4: Document Control

• Section 5: Auditing

• Section 6: Construction Environmental Management Plans

o Appendix 6A: Dredging for Sea Disposal Protocol

o Appendix 6B: Dust Management Plan

• Section 7: Site Emergency Response

o Appendix 7A: Emergency Response Plan

• Section 8: Site Waste Management Plan

• Section 9: Protocol for Archaeological Discoveries

o Appendix 9A: Protocol for Archaeological Discoveries

• Section 10: Materials Management

o Appendix 10A: Site Map

• Section 11: Habitats and Species Protection

o Appendix 11A: Piling MMO Forms

o Appendix 11B: Spoil Disposal MMO Forms

o Appendix 11C: Spoil Disposal MMO Lookout Locations

• Section 12: In-Air Acoustics

• Section 13: Programming

o Appendix 13A: Construction Programme

• Section 14: Schedule of Mitigation

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Section 1 Page - 1

Construction Environmental Management Document

Section Number 1

Section Title Introduction

Issue 1

Issue Date 15/05/18

Author Jon Ashburner

Approved Fiona Henderson

Document History

Issue Date Reason for Change

1 15/05/18 Issued for Marine Licence Application

1 Introduction This Construction Environmental Management Document (CEMD) has been developed to

facilitate the Phase 4 Development of Invergordon Service Base. It sets out the various

mitigation, guidance and policy requirements of the project, both from the Schedule of

Mitigation and with reference to and incorporation of the Principal Contractor’s environmental

management systems.

Specific mitigation protocols designed for the Phase 4 Development include:

• The Dust Management Plan (DMP);

• The Protocol for Archaeological Discoveries (PAD);

• The Dredging for Sea Disposal Protocol;

• The Breeding Bird Species Protection Plan (BBSPP);

• The Marine Mammal Species Protection Plan (MMSPP)

• The Otter Species Protection Plan (OSPP); and

• The Diadromous Fish Species Protection Plan (DFSPP).

1.1 Implementation

The implementation of the CEMD will be through risk assessed method statements (RAMS),

the construction contractor’s environmental management system, and the direct application

of Construction Environmental Management Plans (CEMPs) identified within this document.

1.2 Updates

The CEMD is a live document and will be regularly updated as discussed in Section 4. There

will be a review prior to the start of each new phase of construction.

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Section 2 Page - 1

Construction Environmental Management Document

Section Number 2

Section Title Background

Issue 1

Issue Date 15/05/18

Author Jon Ashburner

Approved Fiona Henderson

Document History

Issue Date Reason for Change

1 15/05/18 Issued for Marine Licence Application

2 Background

2.1 Licensing

The Phase 4 Development is subject to two Marine Licences under the Marine (Scotland) Act

2010 these are for:

• Dredging and sea disposal of spoil; supported by a Best Practicable Environmental

Option (BPEO) study.

• The construction of the Phase 4 Development; supported by an Environmental Impact

Assessment Report (EIAR) as required by the Marine Works (Environmental Impact

Assessment) (Scotland) Regulations 2017.

The following licence is required Marine Scotland, and an application will be submitted in due

course:

• European Protected Species (EPS) licence for disturbance to cetaceans.

The following licence will be required from SEPA. This licence will be applied for once an

appropriate level of detail in the design is available:

• The Water Environment (Controlled Activities) (Scotland) Regulations 2011 (CAR),

licence for the discharge of surface water from the completed works.

The following licences may be required pending further investigation, and will be applied for

through SNH and SEPA respectively if necessary:

• An EPS licence for disturbance to otters.

• CAR licence or registration for the discharge or abstraction of water during

construction.

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Section 2 Page - 2

2.2 Basis

The main aspects of the CEMD have been extracted from the Invergordon Service Base

Phase 4 Development EIAR, prepared by Affric Limited (2018) to support the Marine Licence

Applications. Further detail, including the basis behind the mitigation outlined in this

document is provided in the EIAR.

Mitigation to avoid and minimise potential environmental impacts associated with the

Phase 4 Development aligns to current industry best practice, and the following guidance

documents:

1. Construction Environmental Management Process for Large Scale Projects [The

Highland Council, 2010];

2. PPG 1: Understanding your Environmental Responsibilities – Good Environmental

Practice [NIEA et al., 2013];

3. GPP 5: Works and Maintenance In or Near Water [Environment and Heritage Service

et al., 2017];

4. PPG 6: Working at Construction and Demolition Sites [Environment Agency et al.,

2012];

5. PPG 7: Safe Storage – The Safe Operation of Refuelling Facilities [NIEA, SEPA, et al.,

2011b];

6. PGG 18: Managing Fire Water and Major Spillages [SEPA et al., 2000];

7. GPP 21: Pollution Incident Planning [NIEA et al., 2017];

8. PPG 22: Incident Response – Dealing with Spills [NIEA, SEPA, & Natural Resources

Wales, 2011];

9. PPG 26: Safe Storage – Drums and Intermediate Bulk Containers [NIEA, SEPA, et al.,

2011a];

10. Alien invasive Species and the Oil and Gas Industry Guidance for Prevention and

Management [IPIECA & OGP, 2010];

11. Joint Nature Conservation Committee (JNCC), Statutory nature conservation

agency protocol for minimising the risk of injury to marine mammals from piling

noise [Joint Nature Conservation Committee, 2010];

12. BS EN 5228- 1:3009 + A1 2014: Code of Practice for Noise and Vibration Control on

Construction and Open Sites [British Standards Institute, 2014];

13. Guidance on the Assessment of Dust from Demolition and Construction [IAQM, 2014];

14. Guidance on Air Quality Monitoring in the Vicinity of Demolition and Construction

Sites [IAQM, 2012];

15. CIRIA: Coastal and Marine Environmental Site Guide [CIRIA, 2015];

16. Guidance Note: Controlling Light Pollution and Reducing Lightning Energy

Consumption [Scottish Executive, 2007];

17. Ecology of the European Otter, conserving Natura 2000 Rivers Ecology Series [Chanin,

2003];

18. Scottish Wildlife Series: Otters and Development [SNH, 2010];

19. Roads and Transport Guidelines for New Developments [The Highland Council, 2013];

and

20. Planning for Transport: Planning Advice Note – PAN 75 [Scottish Executive, 2005].

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Section 2 Page - 3

2.3 References

British Standards Institute. (2014). BS EN 5228-1:2009 +A1 2014: Code of practice for noise and

vibration control on construction and open sites. London, UK: British Standards Institute.

Chanin, P. (2003). Ecology of the european otter. In (pp. 68). Peterborough: English Nature.

CIRIA. (2015). Coastal and marine environmental site guide In (pp. 180): CIRIA.

Environment and Heritage Service, SEPA, & Environment Agency. (2017). GPP5: Works and

Maintenance in or Near Water. Retrieved from

http://www.netregs.org.uk/environmental-topics/pollution-prevention-guidelines-

ppgs-and-replacement-series/guidance-for-pollution-prevention-gpps-full-list/.

Environmental Agency, NIEA, & SEPA. (2012). PPG 6: Work at Construction and Demolition Sites.

Retrieved from http://www.netregs.org.uk/environmental-topics/pollution-

prevention-guidelines-ppgs-and-replacement-series/guidance-for-pollution-

prevention-gpps-full-list/.

IAQM. (2012). Guidance on Air Quality Monitoring in the Vicinity of Demolition and Construction

Sites. Retrieved from London, UK:

IAQM. (2014). Guidance on the Assessment of Dust from Demolition and Construction. Retrieved

from London, UK:

IPIECA, & OGP. (2010). Alien invasive species and the oil and gas industry: Guidance for

prevention and management. Retrieved from London, UK:

Joint Nature Conservation Committee. (2010). Statutory Nature Conservation Agency Protocol

for Minimising the Risk of Injury to Marine Mammals from Piling Noise. Retrieved from

http://jncc.defra.gov.uk/pdf/JNCC_Guidelines_Piling%20protocol_August%202010.pdf

Manap, N., & Voulvoulis, N. (2016). Data analysis for environmental impact of dredging. Journal

of Cleaner Production, 137, 394-404. doi:https://doi.org/10.1016/j.jclepro.2016.07.109

NIEA, SEPA, & Environment Agency. (2011a). PPG 26: Deums and intermediate bulk containers.

In (pp. 20).

NIEA, SEPA, & Environment Agency. (2011b). The safe operation of refuelling facilities: PPG7.

In (pp. 1-30): NIEA, SEPA and Environment Agency.

NIEA, SEPA, & Environment Agency. (2013). Pollution Prevention Guidelines: PPG1 -

Understanding your Environmental Responsibilities - Good Environmental Practices. In

(pp. 1-10): NIEA, SEPA and Environment Agency.

NIEA, SEPA, & Natrual Resources Wales. (2011). PPG 22: Dealing with spills. In (pp. 31).

NIEA, SEPA, & Wales, N. R. (2017). GPP 21: Pollution Incident Response Plans. In (pp. 25).

Scottish Executive. (2005). Planning for Transport - Planning Advice Note - PAN 75. In (pp. 42):

Scottish Executive.

Scottish Executive. (2007). Controlling light pollution and reducing lighting energy

consumption. In (pp. 38): Scottish Executive.

SEPA, Environment Agency, & Environment and Heritage Service. (2000). PGG 18: Managing

fire water and major spillages. In (pp. 6).

SNH. (2010). Scotlands Wildlife: Otters and Development. In (pp. 6): SNH.

The Highland Council. (2010). Construction environmental managment process for large scale

projects. In (pp. 1-22): The Highland Council.

The Highland Council. (2013). Roads and Transport guidelines for new developments. In: The

Highland Council.

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Section 3 Page - 1

Construction Environmental Management Document

Section Number 3

Section Title Roles and Responsibilities

Issue 1

Issue Date 15/05/18

Author Jon Ashburner

Approved Fiona Henderson

Document History

Issue Date Reason for Change

1 15/05/18 Issued for Marine Licence Application

Contents 3 Roles and Responsibilities ........................................................................................................................... 2

3.1 Environmental Management Structure ......................................................................................... 2

3.2 Key Environmental Roles and Responsibilities ........................................................................... 3

3.2.1 PoCF Project Manager ................................................................................................................ 3

3.2.2 Consultant Engineer Project Engineer/Site Supervisor .................................................. 3

3.2.3 Environmental Clerk of Works (ECoW) ................................................................................. 4

3.2.4 Lead Marine Mammal Observer (MMO) .............................................................................. 5

3.2.5 Passive Acoustic Monitoring (PAM) Operator ................................................................... 5

3.2.6 Principal Contractor’s Contract Manager ............................................................................ 6

3.2.7 Principal Contractor’s Environmental Representative..................................................... 6

3.2.8 Principal Contractor Site Manager ......................................................................................... 7

3.2.9 All Workers ...................................................................................................................................... 8

3.3 Implementation ...................................................................................................................................... 9

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Section 3 Page - 2

3 Roles and Responsibilities

3.1 Environmental Management Structure

It is important to define roles with regard to environmental management to ensure that it is

clear to all involved who is responsible for what, and that all issues are covered. Figure 3.1

provides an overview of the interactions between the various parties involved in the

construction of the Phase 4 Development. The ECoW will be employed by Port of Cromarty

Firth (PoCF) and will work closely with PoCF’s Project Manager (PM), Consultant Engineer’s Site

Supervisor (SS), as well as the Principal Contractor’s Site Manager (SM) and Environmental

Representative; to ensure that all the elements of the CEMD are being appropriately

implemented. Descriptions of the various roles with regard to environmental management

and training requirements are provided below.

Due to the timescale of this project it is likely that there will be changes of personnel before

the completion of the build. As such this chapter will refer to job titles only, a list of personnel

and contact details can be found in Appendix 3.A which will be updated as necessary

throughout the project.

Figure 3.1: Organogram of Main Environmental Roles

PoCF

Project Manager

Environmental Support

ECoW

Lead MMO

PAM Operator

Client Engineer

Project Engineer

Site Supervisor

Principal Contractor

Environmental Rep.

Site Manager

Key

Communications Route

Reporting Route

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3.2 Key Environmental Roles and Responsibilities

3.2.1 PoCF Project Manager

Responsibility

The PoCF PM is in overall control of work and as such is responsible for ensuring legal and

regulatory commitments are met. They have the ability to stop work on environmental

grounds.

Duties

Specific environmental duties:

• To appoint the ECoW and ensure they are suitably empowered and resourced to carry out

works required.

• Work with ECoW to ensure the CEMD is kept up to date.

• Have overall responsibility for ensuring that all licences are in place and their requirements

are being met.

• Ensure appropriate cumulative working agreements are in place with Global’s Nigg Energy

Park, if simultaneous dredging and disposal operations are ongoing.

Qualification

The PoCF PM should have an appropriate understanding of the licences, legal requirements

and the CEMD.

3.2.2 Consultant Engineer Project Engineer/Site Supervisor

Responsibility

The Consultant Engineer’s Project Engineer (PE) and Site Supervisor are the main link between

PoCF and the ECoW, to the Principal Contractor as such they will be responsible for ensuring

that the Principal Contractor implements appropriate mitigation, Risk Assessed Method

Statements (RAMS), and other requirements as detailed within the CEMD and as requested by

the ECoW.

Duties

Specific environmental duties include:

• To work with ECoW to update the CEMD as required.

• Ensure environmental matters are included within all regular progress and contract

meetings, with minutes distributed to appropriate parties.

• On agreement with ECoW, instruct the Principal Contractor to carry out environmental

related tasks as deemed appropriate to implement the CEMD and to address any issues

arising.

• To ensure environmental instructions are implemented appropriately by the Principal

Contractor.

Qualification

The Consultant Engineer’s PE and SS should have an appropriate understanding of the

licences, legal requirements, the CEMD, and mitigation measures for proposed construction.

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3.2.3 Environmental Clerk of Works (ECoW)

Responsibility

The ECoW is responsible for ensuring appropriate steps are taken to minimise environmental

impacts and risks.

The ECoW will have the authority to stop works on environmental grounds, until appropriate

corrective actions/mitigation/remediation or controls have been put in place to their

satisfaction to allow works to continue.

Duties

The ECoW duties will include:

• Ensuring the PoCF’s interests are looked after with regard to environmental

performance and commitments.

• Working closely with the PoCF PM, Consultant Engineer’s PE/SS and Principal

Contractor’s Environmental Representative to:

o Ensure that the CEMD is kept up to date.

o Ensure the requirements of the CEMD are implemented appropriately.

o Liaise with regulators, stakeholders and other developments in the

surrounding area, as appropriate.

• Reviewing RAMS produced by the Principal Contractor to ensure they identify and

manage environmental impacts and risks in alignment with the CEMD.

• Ensure that all permits, licences and certificates are in place in advance of any works

commencing, with required periodic reviews.

• Ensure that any licensing requirements are appropriately adhered to, implemented

and/or closed out.

• Keep up to date in changes in environmental legislation that may affect environmental

management during the construction phase.

• Carrying out regular documented inspections/audits of the site to ensure that all work

is being carried out in accordance with the CEMD and RAMS.

• To carry out at least daily, checks to ensure that no environmental issues are arising,

including but not limited to signs of water pollution, fugitive dust, and littering.

• Ensure appropriate inductions, environmental tool box talks, and drills are being

implemented by the Principal Contractor.

• Recognise when a topic specific expert is required and call upon them to provide

support, ensure their competence, and manage their activities on site.

• Manage the Marine Mammal Observers (MMO)/Passive Acoustic Monitoring (PAM)

operators.

• Carry out MMO/PAM operator duties as required.

• Be ready to assist in implementing the Principal Contractors emergency response plan.

• Ensure the PoCF PM and the Consultant Engineer PE/SS are notified of any

environmental incidents.

• Where appropriate, notify statutory authorities of any environmental incident in

association with the Principal Contractor.

• Be the Nominated Contact for any archaeological discoveries made during

construction.

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Section 3 Page - 5

• Carry out investigations and produce reports regarding any environmental incidents,

ensure appropriate corrective/remedial actions are taken, and Learning from

Experience (LFE) information is disseminated.

• In conjunction with the Principal Contractor prepare formal monthly report for

progress meetings, recording significant events, issues, audits, and forthcoming

workloads.

• To maintain an environmental site diary.

Qualifications & Experience

The ECoW should be qualified to degree level (or equivalent) in an appropriate environmental

science or engineering discipline; and be a member of an appropriate Institute. They should

have attended a Joint Nature Conservation Committee (JNCC) Marine Mammal Observers

course and PAM training and have an appropriate experience in a range of environmental

disciplines.

3.2.4 Lead Marine Mammal Observer (MMO)

Responsibility

Responsible for conducting visual watches for marine mammals and assist in the

implementation of the Marine Mammal Mitigation Protocols (Section 11). All MMO activities

and reporting will be co-ordinated through the ECoW.

Duties

• Conduct pre, during, and post noisy activity searches for marine mammals.

• Work with the Principal Contractor, PAM operator and ECoW to agree when works can

be started in line with the Marine Mammal Mitigation Protocols.

• Record and report findings of observations.

• Ensure all marine mammal reporting is appropriately completed, including that of the

PAM operator.

Qualifications

Joint Nature Conservation Committee (JNCC) Marine Mammal Observers course. They should

have a minimum of 3 years’ field experience observing marine mammals, and practical

experience of implementing the JNCC guidelines.

3.2.5 Passive Acoustic Monitoring (PAM) Operator

Responsibility

To operate the PAM and assist in the implementation of the Marine Mammal Mitigation

Protocols (Section 11.3.4). All PAM activities and reporting will be co-ordinated through the

ECoW.

Duties

• Conduct pre, during and post noisy activity PAM searches for marine mammals.

• Ensure PAM equipment is installed correctly, calibrated, maintained and operational.

• Review historic data and produce reports as required.

• Work with the MMO and ECoW to agree when works can be started in line with the

Marine Mammal Mitigation Protocols.

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Section 3 Page - 6

• Ensure all marine mammal reporting is appropriately completed.

Qualifications

Attend Joint Nature Conservation Committee (JNCC) Marine Mammal Observers course and

be trained and experienced in the use of PAM software and hardware and have a detailed

understanding of marine mammal acoustics.

3.2.6 Principal Contractor’s Contract Manager

Responsibility

To act as the main point of contact on behalf of the Principal Contractor.

Duties

• Organise construction of the Phase 4 Development to the specified requirements,

particularly standards of workmanship.

• Ensure that all construction personnel work to the current revisions of technical

information and drawings.

• Clarify specified requirements if necessary.

• Ensure the Contract Programme allows adequate time for the installation of materials

and services and is properly sequenced to achieve quality standards and requirements.

• Ensure interim inspections of measuring equipment are carried out and appropriate

action taken as required.

• Ensure subcontractors’ receive and provide information as required.

• Ensure that all construction personnel have the necessary information to recognise

conforming material, to understand the marking of non-conforming material, to handle

material without damage and to select correct equipment and tools.

• Make recommendations to the Contracts Director regarding the training of personnel.

• Liaise with the Client via the Professional Team (Architect, Engineer etc.) using minute’d

meetings, letter or fax as appropriate.

• Liaise with the Subcontractors via minute’d meetings, letters or fax as appropriate.

• Make periodic on-site inspections where appropriate.

• Handle complaints, initiate appropriate action to deal with the complaint, monitor that

action and follow up with a confirmation in writing of action taken to the complainant.

• Ensure adequate resources are in place to meet the requirements of the CEMD.

Qualifications

The Principal Contractors Contract/Project Manager should be qualified to at least Degree

level in an appropriate engineering discipline and have 10 years practical construction

experience.

3.2.7 Principal Contractor’s Environmental Representative

Responsibility

To act as the main point of contact with regard to environmental issues on behalf of the

Principal Contractor.

Duties

The Principal Contractor’s Environmental Representative’s duties will include:

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Section 3 Page - 7

• Working with the ECoW to ensure the CEMD is up to date, and relevant to proposed

construction techniques.

• Ensuring RAMS for all works and sections of works include environmental

considerations and are agreed with ECoW.

• Support the ECoW in the implementation of all environmental matters.

• Producing, agreeing with the ECoW:

o Procedures required to implement the CEMD.

o Emergency Response Procedures.

• Awareness of all potential impacts and associated mitigation detailed in the EIAR.

• Ensure the necessary protection of onsite ecology and biodiversity.

• Ensure environmental mitigation measures are site specific and are complied with.

• Conduct regular environmental audits of the site:

o Findings should be reported promptly to the project management team

including the PM, SS, SM, and ECoW.

o Work with the ECoW to ensure that any actions identified to improve

environmental performance are implemented.

• Ensure the construction site waste management measures are compliment with Site

Waste Management Plan (Section 8).

o Monthly reports of wastes arising from the site including nature of material,

volumes, and fate (reuse, recycling, disposal, etc).

• Ensure environmental licensing/permits are applied for promptly.

Qualifications

The Principal Contractor’s Environmental Representative should be qualified to at least HND

level in an appropriate environmental science or engineering discipline. In addition, they

should have a minimum of 5 years construction experience and a sound understanding of a

range of environmental issues.

3.2.8 Principal Contractor Site Manager

Responsibility

To act as the main point of contact on site, on behalf of the Principal Contractor.

Duties

• Ensuring Principal Contractor’s staff and resources including sub-contractors and

suppliers are briefed in advance of their arrival to site of relevant logistics, parking,

access protocols, in addition to other general environmental requirements.

• Ensuring RAMS are provided to PoCF for review in a timely fashion, prior to the start

of the relevant works.

• Liaise with and support ECoW in all environmental matters.

• Ensuring implementation of with agreement from the ECoW:

o Procedures required to implement the CEMD,

o Emergency response procedures,

o Environmental site induction training,

o Environmental Tool Box Talks, and

o Environmental incident response drills.

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Section 3 Page - 8

• Attendance, participation, and reporting at regular management meetings, including

the monthly progress meetings and all associated reporting.

• Organise the supervision of the works to the specified requirements and in particular

a good standard of workmanship.

• Ensure all materials are received and inspected.

• Ensure subcontractors comply with the requirements of CEMD.

• Notify the Contracts Manager of non-conforming material.

• Make all necessary arrangements for the correct storage and handling of materials.

• Ensure all necessary walkovers, checks, inspections and tests etc. required by the CEMD

are carried out, completed and recorded.

• Ensure that any queries from construction personnel about the quality of work are

properly answered.

• Ensure that construction personnel allocated for tasks are those with suitable skills and

experience, and recommend operatives for additional training to the Contracts

Manager.

Qualifications

The Principal Contractors Site Manager should be qualified to at least HND level in an

appropriate engineering discipline and have a minimum of 5 years of practical construction

experience.

3.2.9 All Workers

Responsibility

Everyone on site should be empowered to raise concerns and if appropriate stop works on

environmental grounds until the ECoW can review the situation.

Duties

All workers are expected to:

• Read, sign and understand the appropriate RAMS, for the work they are undertaking,

• Raise any queries or concerns with methods or mitigation measures prior to

commencing tasks,

• Carry out works in line with the RAMS,

• Report all environmental incidents including spills to the site management team, and

• Ensure good housekeeping is maintain on site, especially with regard to prevention of

littering.

Qualifications

All workers must attend site induction, briefings and tool box talks relevant to the works they

are undertaking to ensure understanding of environmental as well as health and safety issues.

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Section 3 Page - 9

3.3 Implementation

In reality there is likely to be more than one person performing the ECoW duties, to ensure

appropriate presence on site during environmentally sensitive activities and for holiday cover

etc. This will be appropriately managed with a lead ECoW identified with overall responsibility

and the use of a handover system, likely to take the format of a short report and/or face to

face briefing to ensure that there is awareness of recent activities and any issues arising.

Similarly, with PAM and MMO’s, they may be interchangeable if appropriately trained, however

at least one person will be carrying out MMO activities and one PAM operator during relevant

activities.

Similarly, for other roles any changes will be managed, to ensure consistency.

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Invergordon Service Base Phase 4 Development

Appendix 3A

Appendix 3A – Details of Key Project Personnel

Role Company Name Phone Email

PoCF Project Manager PoCF Calum Slater 07747 805567 [email protected]

Consultant Engineer TBC TBC TBC TBC

Consultant Engineer Project Engineer TBC TBC TBC TBC

Consultant Engineer Site Supervisor TBC TBC TBC TBC

ECoW TBC TBC TBC TBC

Lead MMO TBC TBC TBC TBC

PAM Operator TBC TBC TBC TBC

Principal Contractor Contract Director TBC TBC TBC TBC

Principal Contractor Contract Manager TBC TBC TBC TBC

Principal Contractor Asst Contract Manager TBC TBC TBC TBC

Principal Contractor Site Manager TBC TBC TBC TBC

Principal Contractor Environmental Rep. TBC TBC TBC TBC

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Section 4 Page -1

Construction Environmental Management Document

Section Number 4

Section Title Document Control Process

Issue 1

Issue Date 15/05/18

Author Jon Ashburner

Approved Fiona Henderson

Document History

Issue Date Reason for Change

1 15/05/18 Issued for Marine Licence Application

4 Document Control Process Each Section of the CEMD includes an issue number and the date of update along with the

reason for update on the front of the section. The ECoW will have overall responsibility for the

document and will ensure that the most current version is provided in electronic form to:

• CFPA Project Manager

• Consultant Engineer Project Manager

• Consultant Engineer Site Supervisor

• Principal Contractor Project/Contract Manager

• Principal Contractor Environmental Representative

• Principal Contractor Site Manager

• The Construction site office

• The Port Manager

The CEMD, will be updated during the construction phases to take account of additional detail

as it becomes available as well as learning from experience. Specifically, updates will be made

at the following points:

• Receipt of Marine Licence;

• Appointment of Principal Contractor;

• Receipt of EPS Licence(s);

• Following completion of ecological pre-construction surveys; and

• As required following lessons learned during the construction works.

Any material changes to the content of the CEMD will be discussed and agreed with Marine

Scotland, and relevant Statutory Consultees prior to implementation on site.

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Construction Environmental Management Document

Section Number 5

Section Title Auditing

Issue 1

Issue Date 15/05/18

Author Jon Ashburner

Approved Fiona Henderson

Document History

Issue Date Reason for Change

1 15/05/18 Issued for Marine Licence Application

5 Auditing

5.1 Introduction

Audits will be carried out by the ECoW to ensure that all tasks are being carried out in line with

procedures, the CEMD, Risk Assessed Method Statements, and environmental best practice as

identified within the Schedule of Mitigation. The audits will also verify if the mitigation is

effective in minimising environmental impacts and risks.

5.2 Audit Programme

The frequency of audits is provided in Table 5.1, the aspects audited align to the aspects

identified for each phase of work as discussed in CEMD Section 6. Where two tones are shown

in Table 5.1, it indicates that the audit frequency will be reduced with time as the procedures

becomes embedded, the reduction in frequency will be determined by the ECoW based on

audit performance results.

Audits associated with pollution and waste regulations, will be carried out throughout the

construction period irrespective of what tasks are being completed on the site.

It is noted that there will also be a health and safety audit programme; any environmental

issues identified during which will be reported to the ECoW.

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Table 5.1: Audit Frequency

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5.3 Implementation

Audit forms including checklists will be utilised for each audit type to ensure that all items are

appropriately checked and that audits are recorded in a systematic manner.

Where audits identify areas of improvement, appropriate steps will be taken to implement

these. Improvements requiring immediate action will be immediately raised with the

Consultant Engineer’s Site Supervisor (SS), to allow for actions to be arranged. If immediate

action is not required, then the audit report will be submitted within 24 hours of the audit, to

the SS, and actions agreed at the next site management meeting.

In addition to identifying areas for improvement, areas of good practice will be highlighted

and fed back to allow appropriate recognition to be given.

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Construction Environmental Management Document

Section Number 6

Section Title Construction Environmental Management Plans

Issue 1

Issue Date 15/05/18

Author Jon Ashburner

Approved By Fiona Henderson

Document History

Issue Date Reason for Change

1 15/05/18 Issued for Marine Licence Application

Contents

6 Construction Environment Management Plans ................................................................................... 2

6.1 Introduction ............................................................................................................................................. 2

6.2 Site Set-Up ............................................................................................................................................... 4

6.3 Revetment Toe Dredge ....................................................................................................................... 5

6.4 Revetment Construction ..................................................................................................................... 7

6.5 Rock Armour Removal ......................................................................................................................... 8

6.6 Quay Wall and Anchor Piling ......................................................................................................... 10

6.7 Tie Rod Installation ............................................................................................................................ 11

6.8 Berth Dredging .................................................................................................................................... 12

6.9 Infilling .................................................................................................................................................... 14

6.10 Surfacing ................................................................................................................................................ 16

6.11 Concrete Works ................................................................................................................................... 17

6.12 Drainage ................................................................................................................................................. 18

6.13 Furnishings ............................................................................................................................................ 19

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6 Construction Environment Management Plans

6.1 Introduction PoCF take their environmental responsibilities very seriously and as such will select the

Principal Contractors, in part based on the strength of their environmental credentials detailed

during the tendering process. PoCF have worked closely with Affric Limited from the concept

design stage to ensure environmental impacts have been minimised and will appoint an

Environmental Clerk of Works (ECoW) to support the construction. Atkins, the Consultant

Engineers will continue to ensure that all environmental mitigation measures required within

the design and construction engineering are incorporated. The Principal Contractor will have

an ISO14001 (or equivalent) approved Environmental Management System (EMS), and all

works associated with the construction of the Phase 4 Development will be conducted under

the provisions of this system.

Table 6.1 provides a summary of the aspects associated with each of the construction tasks.

Aspects that will certainly occur and require mitigation and/or monitoring to minimise impacts

are shown in red. Aspects that could have an impact are highlighted in yellow, preventative

measures or monitoring have been identified for these.

Within this section, each stage of the Phase 4 Development construction is discussed in turn,

with respect to each relevant aspect; where appropriate, references to other sections are

provided to avoid the duplication of information. All construction activities other than berth

dredging will be carried out between 7am and 7pm seven days a week, to minimise noise

impacts on local residents.

The input required by the Environmental Clerk of Works (ECoW), Marine Mammal Observer

(MMO) and Passive Acoustic Monitoring (PAM) operator is detailed for each task,

proportionate to the risk involved at that stage of the project. It should be noted however

that all staff have environmental and health and safety responsibilities and will undergo site

induction training and task specific environmental training. Risk Assessed Method Statements

(RAMS) will be in place for specific activities to ensure that appropriate environmental

protection measures are in place throughout. As discussed in Section 3.2.3, the ECoW role is

to ensure appropriate measures are in place and are being adequately implemented.

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Table 6.1: Aspects Associated with Each Task

Aspects

Tasks

Site

Set Up

Revetment

Toe

Dredge

Revetment

Construction

Rock

Armour

Removal

Quay Wall

and Anchor

Piling

Tie

Rods

Berth

Dredging Infilling Surfacing

Concrete

Works Drainage Furniture

In-Air

Acoustics

Air Quality:

Dust

Ornithology

Marine

Mammals

Otters

Diadromous

Fish

Archaeology

Materials and

waste

Traffic

Navigation

Water Quality:

Sedimentation

Pollution

Key

No Issue

Potential Aspect

Aspect

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6.2 Site Set-Up

6.2.1 Water Quality

The operations of the site will give rise to domestic waste waters/sewage which will require

management throughout the construction phase.

There are no local connections to the public sewer in the vicinity of the construction site and

the area for the site welfare facilities is all block paved, hence it does not lend itself to the use

of a septic tank and soak away. The current plan is to store domestic waste waters in tanks,

which will be regularly collected and disposed of by a licenced waste contractor.

6.2.2 Traffic

The 6 approx. accommodation containers and other materials including fencing will be

delivered by road to the site, the number of vehicle movements associated with this phase of

works is not deemed significant, however they will be managed in line with the Framework

Construction Traffic Management Plan (FCTMP).

6.2.3 Pollution

A litter sweep of all existing areas to become part of the construction site and associated

welfare areas, will be completed by PoCF prior to the site being handed over to the Principal

Contractor. This will minimise the chance of litter being dropped into the sea during

construction activities.

The site set up includes the establishment of various facilities including: COSHH stores,

Concrete Wash Out Areas and Refuelling Points. Although not all of the facilities will be utilised

immediately it is important to ensure that their establishment is appropriate to minimise future

pollution risks. All these areas will be established at least 10m from a water course or drain.

Appropriate secondary containment will be incorporated, and spill kits provided in alignment

with guidance as identified in the Schedule of Mitigation (Section 14). Materials will be

managed as per Section 10.

6.2.4 Waste

The accommodation area will give rise to waste throughout the project, in the form of

domestic wastes such as food and packaging, and office wastes such as paper and printer

cartridges. In addition, there will be wastes associated with deliveries to the site such as

packaging, there may also be excess materials which require disposal. Wastes will be

segregated and where possible reused or recycled as detailed in the Waste Management Plan

(Section 8). During site set up appropriate waste receptacles will be placed in the

accommodation area to facilitate recycling.

6.2.5 Environmental Input

During the Accommodation Works the ECoW will be onsite for at least part of each day

Monday to Friday, to carry out checks to ensure that the site set up is appropriate and aligns

with the relevant guidance and mitigation measures, as identified in the Schedule of Mitigation

(Section 14) and to allow any matters arising to be discussed. When not onsite, the ECoW will

be contactable during site working hours to give advice as required.

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6.3 Revetment Toe Dredge Dredging will be carried out at the construction site and may be disposed of at the Sutors spoil

ground if not suitable for reuse. Dredging and sea disposal operations are consented under a

separate Marine Licence and supported by a Best Practicable Environmental Options (BPEO)

assessment. The Dredging for Sea Disposal protocol is provided in Appendix 6A.

6.3.1 Marine Mammals

Injury to marine mammals from spoil disposals are only expected if they are directly under the

boat when it discharges and are struck, by larger sediments/stones. A Spoil Disposal Marine

Mammal Protocol will be implemented during all disposal operations, to ensure animals are

not under the vessel at the time of disposal. The protocol is provided in Section 11.3.4.2.

6.3.2 Diadromous Fish

The EIAR has identified that diadromous fish species are most sensitive to water sediment

loading resulting from dredging and disposal operations during the month of May. This is

because May is the peak of the Atlantic salmon outward smolt migration and conducting

dredging or disposal during this time could result in significant impacts on the species.

As such no dredging or sea disposal operations will be conducted from the 1st to the 31st May

(inclusive) in any year. Further detail is provided in Section 11.4.4.1. In addition, the ECoW will

remain vigilant for signs of mass mortality in diadromous fish species, as detailed in Section

11.4.4.2.

6.3.3 Archaeology

No archaeological artefacts are expected to be present in the revetment toe dredge pocket.

If an item of potential archaeological significance is identified is found during the revetment

toe dredge, the Protocol for Archaeological Discoveries will be implemented, as described in

Section 9.

6.3.4 Materials and Waste

Dredging will give rise to 10,000m3/ 20,000 wet tonnes of dredging, some or all of which

requiring disposal (depending on suitability for reuse). Disposal will be to the Sutors disposal

site as per the dredging and disposal licence.

6.3.5 Navigation

The disposal of dredged spoil requires the use of a tug boat to tow the spoil barges to the

Sutors Spoil ground for disposal. All vessel movements will be discussed and agreed with the

PoCF Port Manager. All vessels will display appropriate lights and shapes as per the

International Regulations for Prevention of Collisions at Sea (IRPCS). PoCF will issue Notices

to Mariners and Navigation Warnings as appropriate.

6.3.6 Water Quality: Sedimentation

Backhoe dredging to be used, as a low energy technique in shallow waters, the creation of

sediment plumes should be minimal during the revetment toe dredging operations. Material

maybe side swiped into the infill area if suitable for reuse. If this is to occur material will be

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released as close to the seabed as possible to minimise the increase in sediments in the water

column.

The disposal of dredging in the disposal area at the Sutors, will have short term localised

impacts on water quality.

If all materials were to be disposed of to the dredge disposal ground, then this would be

conducted over approximately 4 disposals using bottom opening or split hopper barges.

Experience from maintenance dredging, and the construction of the Phase 3 Development is

that the sediments normally settles out of the water column in less than 30 minutes following

disposal using a bottom opening barge. In this instance approximately 3,000m3 will be

discharged at a time.

The ECoW will carry out visual checks of the dredging and disposal activities to ensure that

sediment plumes are as expected: localised and short lived.

6.3.7 Pollution

Samples of the seabed have been taken and as discussed in the EIAR and BPEO, this confirmed

that soils targeted for disposal at sea do not represent a source of contamination. Validation

sampling and chemical testing will be carried out on dredge samples as per Marine Scotland’s

standard procedures.

If at any point throughout the dredging campaign contamination is suspected in dredged

material; visual or odours indications; the material will not be disposed of until appropriate

checks can be made by the ECoW; if necessary samples will be analysed; to ensure suitability

prior to disposal.

All equipment utilised will be well maintained and regularly inspected to ensure that it isn’t

leaking, fuel, oils or hydraulic fluids. Where practicable hydraulic fluids utilised will be

biodegradable.

Refuelling will be carried out following site procedures. Fuel will be managed as per CEMD

Section 10.

6.3.8 Environmental Input

During the first 2 days of the dredging works an ECoW will be present onsite, to ensure all

mitigation is in place and that there are no issues arising. For the duration of the dredging

works an ECoW will be available to provide advice by phone 24 hours a day and on site at least

37.5 hours a week, and where required environmental tasks will be delegated to appropriately

trained individuals to provide cover when the ECoW is not on site.

MMO (and PAM if required) support will be available for the disposal operations associated

with the revetment toe dredge as discussed in CEMD Section 11.3.4.2.

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6.4 Revetment Construction The revetment will be constructed by placing various grades of rock onto the seabed within

the footprint previously dredged. Rock armour protection will be placed on the exposed

frontage of the revetment along both western and northern extents. It is assumed that the

rock and geotextile membrane will be delivered by road, with the materials deposited on site

for placement by machinery including long reach excavators.

6.4.1 In-Air Acoustics

The use of dump trucks, and excavators, to form the revetments, together with the end tipping

of the stone will give rise to in-air noise. All machinery will be well maintained, in order to

minimise noise emissions, and vehicles and plant will be fitted with white noise reversing

alarms.

The predictive noise modelling did not indicate that revetment construction will give rise to

nuisance effects, but it is one of the noisier activities. As discussed in Section 12 the ECoW will

visit noise sensitive receptors during operations to qualitatively assess the potential to cause

a nuisance noise effect. Quantitative noise monitoring at the noise sensitive receptors during

the revetment construction operations may be required at the ECoW’s discretion, in order to

verify the results of the predictive noise model.

6.4.2 Air Quality: Dust

All vehicles delivering materials to the site will be covered to minimise the spread of dust. In

order to meet engineering requirements, the rock used for the revetment construction will be

clean, free of debris, and low fines and as such has limited potential for dust emissions. If

materials are being stockpiled, and the weather is particularly dry then it may be dampened

to minimise fugitive dust emissions.

Road sweepers will be utilised to minimise the spread of mud and dust on the construction

site and surrounding roads.

Further detail is provided in the Dust Management Plan (DMP), Appendix 6B.

6.4.3 Ornithology

Regular checks for nesting birds will be conducted by the ECoW during the breeding season.

If nests are found, exclusion zones will be established to protect nests from damage and

disturbance. Further detail is provided in Section 11.2.4.

6.4.4 Otters

Experience gained during the Phase 3 Development construction showed that otters quickly

began to utilise the new habitat created by the revetment construction, although they are

unlikely to establish holts, layups, or couches during the construction phase, due to the levels

of disturbance. As such, plant operators and banksmen will maintain a watching brief for otters,

particularly when recommencing works in the morning, or after a weekend. Further details are

provided in Section 11.5.4.

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6.4.5 Traffic

Approximately 194,000 tonnes of materials will be delivered by road, requiring 540 lorry

movements per week over 36 weeks period, with peak movement of 108 lorries a

day. Quantities to be finalised when design is completed. Deliveries may be staggered as per

the programme.

As discussed in the FCTMP, deliveries will come from the west along the B817, to minimise the

distance travelled through the town.

Delivery lorries will be checked for stones trapped between double wheels and in treads prior

to departure from the quarry or the development site.

6.4.6 Water Quality: Sedimentation

In order to meet engineering requirements, the rock used for the revetment construction will

be clean, free of debris, and low fines. This will also reduce the potential to increase water

column sediment loading. The ECoW will monitor operations and take appropriate action if

excessive sediment plumes are observed.

6.4.7 Pollution

All equipment utilised will be well maintained and regularly inspected to ensure that it isn’t

leaking, fuel, oils or hydraulic fluids. Where practicable hydraulic fluids utilised will be

biodegradable.

Refuelling will be carried out in the designated areas, following site procedures. Materials will

be managed as per CEMD Section 10.

6.4.8 Environmental Input

The ECoW will be on site during the revetment construction works, to a carry out ecological

watching briefs, and sedimentation observations. The ECoW will be onsite approximately 37.5

hours a week for the first 2 weeks to ensure all mitigation measures are being appropriately

implemented and are effective.

As the task is repetitive once all procedures have been established the ECoW support level will

be reduced, however the ECoW will be onsite at least three times a week to carry out

appropriate audits and monitoring and be available to provide advice by phone as required.

6.5 Rock Armour Removal The rock armour currently in place along the western edge of the existing Phase 3

Development will need to be removed where the new and existing structures interface. The

rock armour will be removed using long reach excavators which will work from land but may

require to be deployed on a barge.

6.5.1 In-Air Acoustics

The use of excavators and dump trucks on the site to remove rock armour, and the movements

of rock will give rise to in-air noise. Rocks will be placed as opposed to dropped as much as

practicable to minimise the energy and associated sound pressure levels of rock on rock

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interactions. All machinery will be well maintained, in order to minimise noise emissions, and

vehicles and plant will be fitted with white noise reversing alarms.

The predictive noise monitoring did not indicate that this will give rise to nuisance effects.

6.5.2 Ornithology

The existing rock armour is known be utilised as a nesting area for breeding birds, including

eider ducks, gulls, and oyster catchers. As such there is the potential for the rock armour

removal works to disturb breeding birds, as well damage or destroy their nests.

Rock armour removal will ideally be scheduled to avoid the breeding bird season of March to

August in so far as possible. Where it is not possible to completely avoid the breeding season,

operations will aim to commence before the start of the season. Pre-construction breeding

bird surveys will take place no more than 48hr prior to the start of rock armour removal works.

If there is a need to stockpile rock armour during the bird breeding season, the stockpiles will

be fenced off to dissuade birds from nesting in the stored material.

Further detail is provided in Section 11.2.4.

6.5.3 Otters

If otters are utilising the existing rock armour, then there is the potential for them to be

disturbed or injured during its removal. Section 11.5 of the CEMD provides full details of the

work being undertaken to establish an understanding of the otter use of the area. If required

a European Protected Species (EPS) licence will be sought and full mitigation plan developed.

Regardless of the survey findings, the ECoW will carry out visual checks of the rock armour

immediately prior to its removal to check that there are not otters present to avoid potential

injury. Plant operators and banksmen will conduct a watching brief for otters during the

operations. Further details are provided in Section 11.5.4.

6.5.4 Materials and Waste

The rock armour removed from the existing revetment will be re-used as rock armour for the

new Phase 4 Development revetments.

6.5.5 Pollution

A litter sweep of the rock armour will be completed by the Principal Contractor prior to rock

armour removal, to minimise the chance of litter being dropped into the sea when the rock

armour is removed.

All equipment utilised will be well maintained and regularly inspected to ensure that it isn’t

leaking, fuel, oils or hydraulic fluids. Where practicable hydraulic fluids utilised will be

biodegradable.

Refuelling will be carried out in the designated areas, following site procedures. Materials will

be managed as per CEMD Section 10.

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6.5.6 Environmental Input

The ECoW will be on site during the rock armour removal works, to a carry out ecological

surveys and watching briefs. An ornithologist and otter specialist will conduct pre-construction

surveys. The ECoW will be onsite approximately 37.5 hours a week for the first 2 weeks to

ensure all mitigation measures are being appropriately implemented and are effective.

As the task is repetitive once all procedures have been established the ECoW support level will

be reduced, however the ECoW will be onsite at least three times a week to carry out

appropriate audits and monitoring and be available to provide advice by phone as required.

6.6 Quay Wall and Anchor Piling The Phase 4 Development quay wall will be of combi-wall formation and comprise of around

82, 24mm thick tubular piles of circa 2.032m diameter, with double AZ-18 infill sheet piles

between the tubular sections. Marine piling works will be conducted using a vibro hammer

where ever possible. However, ground conditions are such that an impact hammer will also

be required to drive the piles to their design depth.

6.6.1 In-Air Acoustics

The use of vibro and impact hammers will give rise to intermittent in-air noise emissions. Noise

modelling predicted that this will not result in nuisance effects. However, in line with best

practice guidance, the modelling utilised sound level equivalent calculations (which in effect

are an average noise level over a given time period), and as such don’t indicate the scale of

the intermittent peak sound pressure levels.

Hence, the ECoW will visit noise sensitive receptors during piling operations, in order to make

a qualitative assessment of whether piling noise has the potential to cause a nuisance effect.

Quantitative noise monitoring at the noise sensitive receptors during the piling operations

may be required at the ECoW’s discretion, in order to verify the results of the predictive noise

model and to understand the peak sound pressure levels. Further detail is provided in Section

12.

All plant and equipment will be well maintained in line with industry best practice, to ensure

noise emissions are minimised.

6.6.2 Marine Mammals

The piling will give rise to underwater noise, which could cause disturbance and injury to

marine mammals. In order to mitigate this risk, marine mammal observations and passive

acoustic monitoring will be employed to ensure marine mammals are not in the within 500m

of the piling barge when the operations commence. Further detail is provided in Section

11.3.4.1: Piling Marine Mammal Protocol.

Underwater noise monitoring of vibro piling operations may be conducted, in order to

ascertain whether the noise levels are low enough to reduce the level of marine mammal

mitigation from that provided for the impact piling operations. Any amendments to the Piling

Marine Mammal Protocol will be agreed with Marine Scotland and SNH prior to

implementation.

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6.6.3 Navigation

Vessel movements will include the delivery of piles and tie rods on bulk cargo vessels, and a

spud-leg piling barge which will be manoeuvred by tugs. All vessel movements will be

discussed and agreed with the PoCF Port Manager. All vessels will display appropriate lights

and shapes as per the International Regulations for Prevention of Collisions at Sea (IRPCS).

PoCF will issue Notices to Mariners as and Navigation Warnings as appropriate.

6.6.4 Pollution

All equipment utilised will be well maintained and regularly inspected to ensure that it isn’t

leaking, fuel, oils or hydraulic fluids. Where practicable hydraulic fluids utilised will be

biodegradable.

Refuelling will be carried out in the designated areas, following site procedures. Materials will

be managed as per CEMD Section 10.

6.6.5 Environmental Input

During the first 2 weeks of the piling works, an ECoW will be present onsite, to carry out noise

monitoring, ensure appropriate mitigation is in place, and that there are no issues arising. For

the duration of the piling works an ECoW will be available to provide advice by phone at all

times and it is anticipated to be onsite 37.5 hours a week, where required environmental tasks

will be delegated to appropriately trained individuals to provide cover when the ECoW is not

on site.

MMO/PAM support will be in place for the duration of the piling works to implement the Piling

Marine Mammal Protocol appropriately (CEMD Section 11.3.4.1).

6.7 Tie Rod Installation Where technically feasible the design will utilise one row of tie rods to connect the quay wall

combi-wall formation to the anchor wall. These tie rods are anticipated to be installed above

low water and will be buried with engineering fill.

6.7.1 Pollution

All equipment utilised will be well maintained and regularly inspected to ensure that it isn’t

leaking, fuel, oils or hydraulic fluids. Where practicable hydraulic fluids utilised will be

biodegradable.

Refuelling will be carried out in the designated areas, following site procedures. Materials will

be managed as per CEMD Section 10.

6.7.2 Environmental Input

For the duration of the piling works an ECoW will be available to provide advice by phone at

all times and it is anticipated to be onsite 37.5 hours a week, where required environmental

tasks will be delegated to appropriately trained individuals to provide cover when the ECoW

is not on site.

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6.8 Berth Dredging Dredging of the berth and associated navigational areas will be carried out to -12m Chart

Datum. The volume of material to be dredged is approximately 100,000m3. This is anticipated

to utilise a cutter-suction hopper dredger. It is planned that arisings from the berth dredge

will be used as infill material, provided that the material is structurally suitable. It is predicted

that 40-60% of the arisings will be suitable for re-use. The remaining 40,000 to 60,000m3 of

spoil will be sent for sea disposal at the Sutors spoil ground.

It is noted that aspects associated with the reuse of dredged spoil for infilling are considered

in Section 6.9; this section only considers the dredging and disposal aspects.

Dredging for sea disposal operations are consented under a separate Marine Licence and

supported by a Best Practicable Environmental Options (BPEO) assessment. The Dredging for

Sea Disposal Protocol is provided in Appendix 6A.

6.8.1 In-Air Acoustics

The use of cutter suction dredger ships, together with associated vessel movements will give

rise to in-air noise. Due to the scale of the berth dredging and expense of the equipment

utilised, the works are anticipated to operate on a 24/7 basis.

The predictive noise modelling did not indicate that this will give rise to nuisance effects. This

is due to the distances between the noise source and the sensitive receptors.

All vessels and machinery will be well maintained, in order to minimise noise emissions.

6.8.2 Marine Mammals

Injury to marine mammals from spoil disposals are only expected if they are directly under the

boat when it discharges and are struck, by larger sediments/stones. A Spoil Disposal Marine

Mammal Protocol will be implemented during all disposal operations, to ensure animals are

not under the vessel at the time of disposal. The protocol is provided in Section 11.3.4.2.

6.8.3 Diadromous Fish

The EIAR has identified that diadromous fish species are most sensitive to water sediment

loading resulting from dredging and disposal operations during the month of May. This is

because May is the peak of the Atlantic salmon outward smolt migration and conducting

dredging or disposal during this time could result in significant impacts on the species.

As such no dredging or sea disposal operations will be conducted from the 1st to the 31st May

(inclusive) in any year. Further detail is provided in Section 11.4.4.1. In addition, the ECoW will

remain vigilant for signs of mass mortality in diadromous fish species, as detailed in Section

11.4.4.2.

6.8.4 Archaeology

No archaeological artefacts are expected to be present in the berth dredge pocket. If an item

of potential archaeological significance is identified is found during the revetment toe dredge,

the Protocol for Archaeological Discoveries will be implemented, as described in Section 9.

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6.8.5 Materials and Waste

Dredging will give rise to 40,000-60,000m3/80,000-120,000 wet tonnes of dredging requiring

disposal. Disposal will be to the Sutors disposal site as per the dredging and disposal licence.

The decision to dispose of the dredging’s is documented in the BPEO which accompanied the

dredging licence. The possibility to reuse all the material was ruled out due to its material

consistency giving rise to settlement issues for the Phase 4 Development land reclamation

area.

6.8.6 Navigation

The disposal of dredged spoil requires the vessel to transit to and from the Sutors Spoil ground

for disposal. Where a cutter suction dredge is used, the vessel will be restricted in ability to

manoeuvre during dredging operations. All vessel movements will be discussed and agreed

with the PoCF Port Manager. All vessels will display appropriate lights and shapes as per the

International Regulations for Prevention of Collisions at Sea (IRPCS). PoCF will issue Notices

to Mariners and Navigation Warnings as appropriate.

6.8.7 Water Quality: Sedimentation

Suction dredgers extract water with the dredged sediment, and as such a degree of overflow

is necessary to fill the hoppers, resulting in localised increases in water column sediment

loading. Previous observations of such activities indicate that the resulting sediment plumes

dispersed quickly and remained in close proximity to the works. This notwithstanding, dredger

masters will be encouraged to optimise their equipment to minimise the requirement for

overflowing. The ECoW will monitor sediment plumes during initial dredging works.

The disposal of spoil in the disposal area at the Sutors, will have short term localised impacts

on water quality. It is estimated that between 40,000 – 60,000m3 of spoil from the berth dredge

will require sea disposal at the Sutors spoil ground. This will be conducted over approximately

9 disposals using bottom opening doors.

Experience from maintenance dredging, and the construction of the Phase 3 Development is

that the sediments normally settles out of the water column in less than 30 minutes following

disposal using a bottom opening barge. In this instance approximately 7,000m3 will be

discharged at a time. The ECoW will monitor the resulting plumes during the initial disposals.

6.8.8 Pollution

Samples of the seabed have been taken and as discussed in the EIAR and BPEO, this confirmed

that soils targeted for disposal at sea do not represent a significant source of contamination.

Validation sampling and chemical testing will be carried out on dredge samples as per Marine

Scotland’s standard procedures.

If at any point throughout the dredging campaign contamination is suspected in dredged

material; visual or odours indications; the material will not be disposed of until appropriate

checks can be made by the ECoW; if necessary samples will be analysed; to ensure suitability

prior to disposal.

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All equipment utilised will be well maintained and regularly inspected to ensure that it isn’t

leaking, fuel, oils or hydraulic fluids. Where practicable hydraulic fluids utilised will be

biodegradable. Refuelling will be carried out in the designated areas, following site

procedures. Fuel will be managed as per CEMD Section 10.

6.8.9 Environmental Input

During the first 2 days of the dredging works an ECoW will be present onsite, to ensure all

mitigation is in place, and monitor sediment plumes during dredging and disposal works. For

the duration of the dredging works an ECoW will be available to provide advice by phone 24

hours a day and on site at least 37.5 hours a week, and where required environmental tasks

will be delegated to appropriately trained individuals to provide cover when the ECoW is not

on site.

MMO (and PAM if required) support will be available for the disposal operations associated

with the revetment toe dredge as discussed in CEMD Section 11.3.4.2.

6.9 Infilling Infill material will be placed within the area formed by the bounding revetment structures, and

the combi-piled wall to the south. This infill will form the main reclamation and will provide

the laydown area of the Phase 4 Development. The material utilised will include dredge arisings

which are suitable for inclusion within the structure, in addition to appropriately sourced

engineering grade fill materials either of marine or terrestrial origin.

Infill materials from marine sources (including dredged spoil) will be pumped directly from a

ship into the reclamation area as a slurry with a high-water content. Materials from terrestrial

sources may be delivered from the ship dry, using conveyor belts.

6.9.1 In-Air Acoustics

The use of dump trucks, excavators, bulldozers, and rollers to place and compact the fill

material, together the vessel noise from the delivery vessel will result in increased in-air noise

emissions. All machinery will be well maintained, in order to minimise noise emissions, and

vehicles and plant will be fitted with white noise reversing alarms.

The predictive noise modelling did not indicate that infilling will give rise to nuisance effects,

but it is one of the noisier activities. As discussed in Section 12 the ECoW will visit noise

sensitive receptors during operations to qualitatively assess the potential to cause a nuisance

noise effect. Quantitative noise monitoring at the noise sensitive receptors during the infilling

operations may be required at the ECoW’s discretion, in order to verify the results of the

predictive noise model.

6.9.2 Air Quality: Dust

The infilling process may result in large surfaces of unconsolidated fine grained fill materials

being exposed for extended periods. It is also possible that large volumes of fill material will

need to be temporarily stockpiled on site, in order to facilitate the construction phasing.

During periods of dry windy weather, the surface of the exposed fill materials and stockpiles

dry rapidly, potentially releasing significant fugitive dust emissions. In order to mitigate this,

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any exposed fill material and stock stockpiles will be kept damp using mobile sprayers or

sprinkler systems as appropriate.

Road sweepers will be utilised to minimise the spread of mud and dust on the construction

site and surrounding roads.

The ECoW will provide a qualitative assessment of fugitive dust emissions during infilling

operations, in order to ascertain the effectiveness of the dust mitigation measures. At the

ECoW’s discretion, the principal contractor may be requested to install dust monitoring

stations at the northern and eastern site construction site boundaries, and at the access gate

onto the B817, to provide a quantitative assessment of the dust mitigation.

Further detail is provided in the Dust Management Plan (DMP), Appendix 6B.

6.9.3 Water Quality

The reclamation process has been designed so as to minimise sedimentation issues in the

surrounding waters. The infill material will be discharged directly into the reclamation area

which will be segregated from the surrounding waters by the revetment and the quay wall.

The construction phasing may require that infilling commences prior to the revetment or quay

wall being completed. In this event temporary revetments will be constructed to isolate the

delivery area, for marine fill material delivered as a slurry. If the dry fill is to be utilised prior to

the revetment or quay wall being completed, silt curtains may be used to isolate the area.

If the fill material is delivered as a slurry, it is necessary to ensure that sufficient residence time

in the reclamation area is provided, to allow the material to drop out of the slurry, before the

excess water is released. This will be achieved through a series of bunds, and a weir system,

designed to slow the water as it travels from the delivery point to the water discharge point.

The ECoW will maintain a watching brief of the water discharge and monitor any sediment

plumes in the waters surrounding the development. If deemed necessary, the ECoW will stop

works, and ensure the arrangements are improved before infilling resumes.

6.9.4 Pollution

All fill materials will be tested to ensure they are not contaminated prior to acceptance at the

site.

All equipment utilised will be well maintained and regularly inspected to ensure that it isn’t

leaking, fuel, oils or hydraulic fluids. Where practicable hydraulic fluids utilised will be

biodegradable.

Refuelling will be carried out in the designated areas, following site procedures. Materials will

be managed as per CEMD Section 10.

6.9.5 Environmental Input

The ECoW will be onsite approximately 37.5 hours a week for the first 2 weeks to ensure

appropriate mitigation measures are being appropriately implemented and are effective. As

the task is repetitive once all procedures have been established the ECoW support level will

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be reduced, however the ECoW will be onsite at least two times a week to carry out appropriate

audits and monitoring and be available to provide advice by phone as required.

6.10 Surfacing A 30m wide reinforced concrete apron slab to the rear of the quay wall will provide one

continuous surfacing between Berth 5 and Berth 6 with the aim of facilitating loading and

unloading of cargo. Geotextile membranes and potentially shallow material containment

products will be utilised to minimise material movement over the rest of Phase 4. It will then

be finished with crushed stone.

Aspects associated with installation of the concrete slab are considered in Section 6.11; this

section only refers to the crushed stone finish.

6.10.1 In-Air Acoustics

The use of dump trucks, excavators, and rollers to form the revetments, together with the end

tipping of the stone will give rise to in-air noise. All machinery will be well maintained, in order

to minimise noise emissions, and vehicles and plant will be fitted with white noise reversing

alarms.

The predictive noise modelling did not indicate that surfacing will give rise to nuisance effects,

but it was the activity identified as resulting in the highest noise levels at the receptors. As

discussed in Section 12 the ECoW will visit noise sensitive receptors during operations to

qualitatively assess the potential to cause a nuisance noise effect. Quantitative noise

monitoring at the noise sensitive receptors during the surfacing operations may be required

at the ECoW’s discretion, in order to verify the results of the predictive noise model.

6.10.2 Air Quality: Dust

All vehicles delivering materials to the site will be covered to minimise the spread of dust. Due

to the material specification required to minimise sedimentation issues, the material will have

a low fines/dust content. If materials are being stockpiled, and the weather is particularly dry

then it may be dampened to minimise fugitive dust emissions.

Road sweepers will be utilised to minimise the spread of mud and dust on the construction

site and surrounding roads.

Further detail is provided in the Dust Management Plan (DMP), Appendix 6B.

6.10.3 Traffic

As discussed in the FCTMP, deliveries will come from the west along the B817, to minimise the

distance travelled through the town.

The delivery lorries will be checked for stones trapped between double wheels and in treads

prior to departure from the quarry or the development site.

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6.10.4 Pollution

All equipment utilised will be well maintained and regularly inspected to ensure that it isn’t

leaking, fuel, oils or hydraulic fluids. Where practicable hydraulic fluids utilised will be

biodegradable.

Refuelling will be carried out in the designated areas, following site procedures. Materials will

be managed as per CEMD Section 10.

6.10.5 Environmental Input

The ECoW will be onsite approximately 37.5 hours a week for the first 2 weeks to ensure all

mitigation measures are being appropriately implemented and are effective.

As the task is repetitive once all procedures have been established the ECoW support level will

be reduced, however the ECoW will be onsite at least three times a week to carry out

appropriate audits and modelling and be available to provide advice by phone as required.

6.11 Concrete Works Concrete will be used in numerous aspects of the Phase 4 Development, including installation

of the four large bollard bases, the cope beam, the quayside slab, and other foundations for

utilities.

Concrete will be delivered to site as ready mix and either mass poured directly or utilised to

pre-cast components for later installation.

6.11.1 Traffic

As discussed in the FCTMP, deliveries will come from the west along the B817, to minimise the

distance travelled through the town.

The delivery lorries will be checked for stones trapped between double wheels prior to

departure from the development site.

6.11.2 Pollution

Equipment utilised in the placing of concrete will require washing, including excavator buckets,

concrete pumps, and gravity fed hoppers. Concrete wash water is highly alkaline, and hence

needs to be contained. As such concrete washout will only be carried out in a dedicated area.

The concrete washout area will be at least 10m from the water nearest watercourse or drain

and include appropriate containment to prevent release to the environment.

Concrete wash water will be settled to remove solids and if practicable, the water will be

reused. If it is not possible to reuse the wash water; an appropriate treatment route will be

identified.

Concrete lorries will only be permitted to wash their shoots on the site.

Appropriate shuttering and edge protection will be in place to ensure that concrete works in

close proximity to the quay edge does not seep into the water column. The ECoW and Site

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Supervisor will inspect all shuttering to be used during ‘over-water’ pours of concrete such as

the cope beam, to ensure it is adequately sealed prior to the pour commencing.

All equipment utilised will be well maintained and regularly inspected to ensure that it isn’t

leaking, fuel, oils or hydraulic fluids. Where practicable hydraulic fluids utilised will be

biodegradable.

6.11.3 Environmental Input

The ECoW will be onsite for the first week of all major concrete works to ensure that the

appropriate mitigation and procedures are in place. After which they will be onsite twice a

week to carry out audits and checks. The ECoW will be contactable by phone for the duration

of the works, and available to conduct shuttering inspections as required.

6.12 Drainage The Phase 4 Development laydown area will be drained utilising a French drainage system in

conjunction with the quayside apron slab runoff, captured via channel drains installed to the

rear of the slab. Both systems will connect into the one drainage discharge system, anticipated

to be through appropriately sized oil and silt interceptors with penstock control, thus

permitting cessation of flow into the Firth if required.

6.12.1 Air Quality: Dust

Excavations for the installation of drainage infrastructure may lead to fugitive dust emissions,

particularly with regard track out from the site. Road sweepers will be utilised to minimise the

spread of concrete dusts on the construction site and surrounding roads.

6.12.2 Traffic

As discussed in the FCTMP, deliveries will come from the west along the B817, to minimise the

distance travelled through the town.

The delivery lorries will be checked for stones trapped between double wheels prior to

departure from the development site.

6.12.3 Water Quality: Sedimentation

The surface water drains and associated outfalls will require a licence under The Water

Environment (Controlled Activities) (Scotland) Regulations 2011 (CAR). This will be applied for

before the drains are installed. The provision of the oil and silt interceptor will prevent

sediment loading effects.

6.12.4 Pollution

As detailed above, the drainage system will be CAR Licenced and include an oil interceptor.

The provision of the penstock valve allows the system to be isolated, preventing oils and other

contaminants which enter the drains from entering the marine environment.

All equipment utilised will be well maintained and regularly inspected to ensure that it isn’t

leaking, fuel, oils or hydraulic fluids. Where practicable hydraulic fluids utilised will be

biodegradable.

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Refuelling will be carried out in the designated areas, following site procedures. Materials will

be managed as per CEMD Section 10.

6.12.5 Environmental Input

The ECoW will be involved in reviewing the suitability of the drainage design and will carry out

audits and checks during the installation works as required. The ECoW will be contactable by

phone for the duration of the works.

6.13 Furnishings Furnishings cover a range of activities which will be conducted toward the end of the

construction phase, such as the installation of bollards, fendering, lighting and other services

not mentioned in previous sections. These activities carry a relatively low environmental risk;

however, the following general provisions will be made.

6.13.1 Air Quality: Dust

Excavations for the installation of services and other furnishings may lead to fugitive dust

emissions, particularly with regard track out from the site. Road sweepers will be utilised to

minimise the spread of concrete dusts on the construction site and surrounding roads.

6.13.2 Traffic

As discussed in the FCTMP, deliveries will come from the west along the B817, to minimise the

distance travelled through the town.

The delivery lorries will be checked for stones trapped between double wheels prior to

departure from the development site.

6.13.3 Otter

If otters are utilising the potential layup at the south east corner of Phase 3, then there is the

potential for them to be disturbed during the fender installation. Section 11.5 of the CEMD

provides full details of the work being undertaken to establish an understanding of the otter

use of the area. If required a European Protected Species (EPS) licence will be sought and full

mitigation plan developed.

6.13.4 Pollution

All equipment utilised will be well maintained a regularly inspected to ensure that it isn’t

leaking, fuel, oils or hydraulic fluids. Where practicable hydraulic fluids utilised will be

biodegradable.

Refuelling will be carried out in the designated areas, following site procedures. Materials will

be managed as per CEMD Section 10.

6.13.5 Environmental Input

Due to the low risks the Environment the ECoW will be onsite only twice a week to carry out

checks and audits. The ECoW will be contactable by phone for the duration of the works.

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Appendix 6A - Page 1

Construction Environmental Management Document

Section Number Appendix 6A

Section Title Dredging for Sea Disposal Protocol

Issue 1

Issue Date 15/05/18

Author Jon Ashburner

Approved Fiona Henderson

Document History

Issue Date Reason for Change

1 15/05/18 Issued for Marine Licence Application

Introduction

110,000m3 of material are to be dredged to construct the Phase 4 Development. Following

analysis of the GI results, it is anticipated that 40-60% of the total dredged spoil volume will

not be suitable for reuse and will require sea disposal at the Sutors spoil ground. This

document lays out the steps to be taken prior to, during and after dredging.

Prior to Dredging

Prior to dredging the following should be completed/ in place:

• A meeting is to take place between the dredging vessel master and the Port Manager

to discuss/agree:

o Transportation routes and timing, to and from the Sutors;

o Communication/Radio Protocols; and

o Harbour General Directions.

• Notices to Mariners, and/or Navigation Warnings issued as appropriate.

• Marine Scotland to be notified of the date of commencement.

• Vessel master to be provided with a copy of all relevant licences.

• Vessel Master and MMO/PAM operators to be provided with copies of the Spoil

Disposal Marine Mammal Protocols (Section 11.3.4.2).

During Dredging for Sea Disposal

During dredging operations, the following should be implemented:

• Marine mammal observations to be carried out as detailed in CEMD Section 11.3.4.2.

• No disposals to be made if marine mammals are within 200m of the dredging barge.

• Transportation to utilise routes agreed with the Port Manager.

• All sea disposals to be made at the Sutors Spoil Ground (CRO19).

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• Samples to be taken in accordance with Marine Scotland instructions.

• If contamination is suspected material will not be disposed of until appropriate checks

have been made.

• All dredging and disposal works to be carried out as detailed within the CEMP.

• Persons authorised by Marine Scotland will be permitted to inspect works.

• The dredger, barges and tugs will exhibit the required lights/shapes at all times.

• Form FEP6 to be completed for each disposal

Disposals will not be carried out in hours of darkness, or when weather or sea conditions are

unsuitable for visual observations, unless PAM is provided at the spoil ground as detailed in

Section 11.3.4.2.

No dredging or sea disposals of dredged spoil will be conducted in the period between the

1st and the 31st May (inclusive) of any year.

Post Dredging

The following will be completed post dredging:

• A written marine mammal report and associated MMO forms shall be submitted to

Marine Scotland.

• Spoil samples and completed FEP 6 forms will be provided to Marine Scotland.

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Appendix 6B - Page 1

Construction Environmental Management Document

Section Number Appendix 6B

Section Title Dust Management Plan

Issue 1

Issue Date 15/05/18

Author Fiona Henderson

Approved Jon Ashburner

Document History

Issue Date Reason for Change

1 15/05/18 Issued for Marine Licence Application

Introduction

Revetment construction, infilling and surfacing all have the potential to give rise to dust, which

can become a nuisance and potentially a health hazard, especially in dry and windy conditions.

Steps to be taken to minimise and monitor dust effects are detailed within this Dust

Management Plan which accompanies the Construction Environmental Management Plans

(CEMPs) provided in Section 6.

Dust Prevention

Revetment construction and surfacing materials will be specified as being low in fines, in order

to meet engineering requirements; this will also reduce the potential for fugitive dust

emissions. All delivery vehicles entering and leaving the site will be covered to prevent dust

being an issue on the public roads.

Infilling materials will have a relatively high fines content and may be delivered to the site in

wet or dry states; wet materials may be piled above the water level and as such can dry out.

Not matter what the source of infill material there will be a need to keep the material damp in

order to prevent fugitive dust emissions.

Mobile sprayers or static sprinkler systems will be utilised during periods of dry weather to

keep stockpiles and other exposed surfaces of infill material wet. The ECoW will take note of

weather forecasts to ensure that measures are in place prior to periods of dry or windy weather.

Infill materials will be covered with geotextiles and surfacing as soon as practicably possible,

to cover up the potential dust source.

Delivery vehicles will follow designated routes, designed to minimise exposure to dusty

materials; this will be achieved by routing vehicles over lock block, hard standing, newly

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Appendix 6B - Page 2

constructed revetment, and surfaced reclamation area such that their wheels do not pick up

materials that could lead to track out.

Minimising Spread and Track-Out

Road sweepers will be employed as required to minimise the spread of materials through the

Invergordon Service Base, and if need be onto the public road.

Dust Monitoring

The ECoW will carry out regular checks of materials which have the potential to give rise to

dust, to ensure that they are kept damp. In addition, inspections of the adjacent areas of the

service base, the site entrance, and the B817 will be carried out to identify if dust is becoming

an issue. The ECoW will carry out spot checks on delivery vehicles to ensure that they are

utilising their covers. If required, appropriate remedial steps shall be taken these may include:

• Wetting of material;

• Increasing resource levels for material damping;

• Additional road sweeping; and

• Reminders to drivers to utilise their vehicle covers.

In event of repeat issues, quantitative dust monitoring techniques will be employed, to monitor

the effectiveness of the dust mitigation provided at the site. This would most likely take the

form of directional passive monitoring, as detailed in the Institute of Air Quality Managements,

Guidance on Air Quality Monitoring in the Vicinity of Demolition and Construction Sites. If

used, dust monitoring stations will be positioned on the northern and eastern boundaries of

the site, proximal to the nearest sensitive receptors, as well as at the site entrance.

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Section 7 Page - 1

Construction Environmental Management Document

Section Number 7

Section Title Site Emergency Response

Issue 1

Issue Date 15/05/18

Author Jon Ashburner

Approved Fiona Henderson

Document History

Issue Date Reason for Change

1 15/05/18 Issued for Marine Licence Application

7 Site Emergency Response

7.1 Introduction Pollution prevention measures have been developed to minimise the risk of an

environmental incident occurring during the Invergordon Service Base Phase 4

Development. These measures combine both the current UK best practice and guidance

from the following documents.

• Construction Environmental Management Process for Large Scale Projects, The

Highland Council (2010).

• PPG 1: Understanding your environmental responsibilities – good environmental

practices [NIEA et al., 2013];

• GPP 5: Works and maintenance in or near water [NIEA et al., 2018];

• PPG 6: Working at construction and demolition sites [NIEA et al., 2012];

• PPG 7: Safe storage – The safe operation of refuelling facilities [NIEA, SEPA, &

Environment Agency, 2011];

• PGG 18: Managing Fire Water and Major Spillages [SEPA et al., 2000];

• GPP 21: Pollution Incident Planning [NIEA et al., 2017];

• PPG 22: Incident Response – Dealing with Spills [NIEA, SEPA, & Natrual

Resources Wales, 2011];

• PPG 26: Safe Storage – Drums and Intermediate Bulk Containers [NIEA et al

2011]; and

• Alien invasive Species and the Oil and Gas Industry Guidance for Prevention and

Management [IPIECA & OGP, 2010].

However, in the unlikely event of an environmental incident occurring, it is important to have a

comprehensive emergency response plan in place in order to minimise the potential impacts.

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7.2 Outline of Procedures The emergency response plan follows the ‘Source – Pathway – Receptor’ model as described

in PPG1. In the event of an environmental incident the following will be prioritised:

• Stop the source of the pollution.

• Interrupt any pathways to the environment.

• Report the incident in as much detail as possible to site management and the

ECoW.

• Clean the contaminated area and recover pollutants.

• Analyse the event to prevent further incidents.

The detailed Emergency Response Plan (ERP) can be found in Appendix 7A.

The site manager and ECoW will ensure all site personnel are trained in the ERP through

regular toolbox talks, drills, and safety briefs.

7.3 References IPIECA, & OGP. (2010). Alien invasive species and the oil and gas industry: Guidance for

prevention and management. Retrieved from London, UK:

NIEA, Environment Agency, & SEPA. (2012). PPG 6: Work at Construction and Demolition

Sites. Retrieved from http://www.netregs.org.uk/environmental-topics/pollution-

prevention-guidelines-ppgs-and-replacement-series/guidance-for-pollution-

prevention-gpps-full-list/.

NIEA, Environment and Heritage Service, SEPA, & Environment Agency. (2018). GPP5: Works

and Maintenance in or Near Water. Retrieved from

http://www.netregs.org.uk/media/1418/gpp-5-works-and-maintenance-in-or-near-

water.pdf?utm_source=website&utm_medium=social&utm_campaign=GPP5%20271

12017.

NIEA, SEPA, & Environment Agency. (2011). PPG 7: The safe operation of refuelling facilities.

In (pp. 30): NIEA, SEPA and Environment Agency.

NIEA, SEPA, & Environment Agency. (2013). PPG 1: Understanding Your Environmental

Responsibilities - Good Environmental Practices. In (pp. 10): NIEA, SEPA and

Environment Agency.

NIEA, SEPA, & Natrual Resources Wales. (2011). PPG 22: Dealing with spills. In (pp. 31).

NIEA, SEPA, & Wales, N. R. (2017). GPP 21: Pollution Incident Response Plans

SEPA, Environment Agency, & Environment and Heritage Service. (2000). PGG 18: Managing

fire water and major spillages. In (pp. 6).

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Appendix 7A – Emergency Response Plan

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ISSUE: 1 Date 11/05/18 Page 1 of 2

Environmental Incident Response Invergordon Service Base

Phase 4 Development

PROCEDURE TO BE FOLLOWED IN THE EVENT OF A SPILLAGE:The following procedures are intended as a guide to dealing with incidents. Staff shall act in accordance with

these procedures whilst applying common sense and ensuring their own health & safety and those of others.

1. If possible, identify the source of the spillage and cut off source, e.g. by closing valve, righting

container etc.

2. Call of help* - Port Radio on 01349 852308 or VHF Ch11

• Key Information to be provided in a clear and concise manner:

o What substance was spilled;

o Approximate volume and time of spillage;

o Accurate location of spill;

o Help required i.e. manpower, machinery, expert advice, disposal, etc; and,

o Whether the spill has reached a drain or watercourse.

3. Identify where spillage has gone to and/or where it may go to. Contain the spillage using

appropriate spill management equipment and absorbents (spill kit); cover any drains which spills

could reach.

4. If there is a risk of the spill reaching a drain, cover or block drain.

5. If spills have or are at risk of entering a drain, then close the appropriate drain isolation valve.

6. If a spill has reached a watercourse the following measures should be applied-

• Place flexible absorbent booms around the spillage to minimise the spread;

• Place absorbent cushions in the affected area inside the booms.

• Call the SEPA Emergency Hotline Number – 0800 80 70 60

7. Clean any contaminated surfaces as soon as possible / immediately. All contaminated materials

should be placed in sealed polythene bags/containers and store within the designated waste

storage area. For spills that have entered the drainage system arrange for the to be pumped out

promptly.

8. Dispose of contaminated materials appropriately in accordance with the site waste management

protocols;

9. Fully complete an Incident Report.

Key Information to be provided in a clear and concise manner (as soon as possible, but within 30 minutes of incident):• What substance was spilled;

• Approximate volume and time of spillage;

• Accurate location of spill;

• All measures taken;

• Help required i.e. manpower, machinery, expert advice, disposal, etc; and

• Whether the spill has reached a watercourse.

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ISSUE: 1 Date 11/05/18 Page 2 of 2

Environmental Incident Response Invergordon Service Base

Phase 4 Development

Key Contact Information

Construction contractor (TBC) using the emergency procedures; contact details located at the back of

the Site Card issued to everyone of site. Contact details are as follows:-

Name Role ContactTBC TBC TBC

TBC TBC TBC

TBC TBC TBC

TBC TBC TBC

TBC TBC TBC

If the spillage is likely to cause pollution, then the ECoW or a Construction contractor staff member will

contact the Scottish Environmental Protection Agency (SEPA) using the emergency hotline number

(0800 80 70 60)

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Invergordon Service Base Phase 4 Development

Section 8 Page -1

Construction Environmental Management Document

Section Number 8

Section Title Site Waste Management Plan

Issue 1

Issue Date 15/05/18

Author Fiona Henderson

Approved Jon Ashburner

Document History

Issue Date Reason for Change

1 15/05/18 Issued for Marine Licence Application

8 Site Waste Management Plan

8.1 IntroductionThe main source of waste during construction works is dredged material, the management of

which is covered in Section 6 and as such will not be covered here. Other wastes including:

cement washings, wood utilised for shuttering, off-cuts of rebar metals and packaging

materials associated with both construction works, and the welfare facilities will also arise

during construction.

The waste hierarchy will be employed throughout the construction works.

8.2 Waste Hierarchy Implementation

8.2.1 Reducing Waste

Where practicable steps will be taken to avoid the production of waste. For example, the use

of reusable water bottles, crockery and cutlery in the welfare facilities, will prevent the need

for single use plastics.

The bulk of material will be delivered in HGV’s without packaging, where practical requests

should be made to suppliers to minimise packaging.

Similarly ordering the correct quantity and types of materials will prevent excess materials

not utilised being disposed of as waste.

8.2.2 Reuse

Where possible materials can be reutilised. For example, wood utilised in shuttering can be

utilised more than once. Cement wash water can be reutilised to wash equipment once it

has been settled out.

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Invergordon Service Base Phase 4 Development

Section 8 Page -2

8.2.3 Recycle Recycling will be facilitated by the segregation of wastes. Clearly marked and labelled waste

receptacles will be provided in designated areas. Wastes suitable for recycling are likely to

include wood, metals, glass, paper, plastics and oils.

8.2.4 Dispose Solid waste not suitable for recycling will be sent to landfill as waste, or special waste,

depending on its constitution. A suitable licensed waste contractor will be employed to

collect wastes for recycling and disposal.

8.3 Cement Washing Cement washings will be carried out in a dedicated area. Washing arisings will be collected

for onsite treatment. This will include settlement and, if required, pH correction. The liquids

will be reused on site as grey water if suitable, or disposed of via a consented discharge

onsite route, if available. Alternatively, they will be tanker’d off site for disposal. The solids

will be disposed of as solid waste.

8.4 Waste Management Waste receptacles (bins and skips) will incorporate lids or covers to protect against vermin

gaining access and wind blowing wastes out of skips.

The principle contractor will put in place procedures for ensuring that appropriate records

are kept for all waste arisings including volumes, categories and waste carriers used, and that

waste transfer notes are retained.

8.5 Monitoring The Environmental Clerk of Works (ECoW) will carry out regular waste compliance audits and

review details of waste arisings to identify areas for opportunity to reduce or recycle more

wastes in conjunction with the Principle Contractor.

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Invergordon Service Base Phase 4 Development

Section 9 Page - 1

Construction Environmental Management Document

Section Number 9

Section Title Protocol for Archaeological Discoveries

Issue 1

Issue Date 15/05/18

Author Jon Ashburner

Approved Fiona Henderson

Document History

Issue Date Reason for Change

1 15/05/18 Issued for Marine Licence Application

9 Protocol for Archaeological Discoveries

9.1 Introduction Underwater archaeology was scoped out of the EIA process as there was no evidence of

archaeological remains being present in the area. However, if artefacts are present, the

activities associated with the Invergordon Service Base Phase 4 Development, particularly

dredging, could impact the historic environment. As such this procedure based on the Protocol

for Archaeological Discoveries (PAD) as established by Wessex Archaeology on behalf of The

Crown Estate, will be implemented on site as a precautionary measure.

9.2 Terms The PAD defines two types of Archaeological discovery:

• ‘Finds’ – an object of archaeological potential; this means it has been impacted by

people and may reveal something of past lives. Eco-artefacts such as animal and

plant remains are also included in finds as they help us to understand the past human

landscape. Finds can either be objects on the sea floor or those brought to the

surface.

• ‘Anomalies’ – are differences in the sea bed (either digital or visual) which could be of

archaeological significance, and need further investigation. Anomalies should always

be treated as significant until determined otherwise.

9.3 Protocol The bathymetric survey and benthic transects conducted during EIA revealed no

archaeological anomalies. No further bathymetry will be conducted during construction so

this protocol will only cover archaeological finds brought to the surface during construction

works.

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Invergordon Service Base Phase 4 Development

Section 9 Page - 2

All site personnel will be briefed on the significance of archaeological finds, and will be

instructed to report any discoveries to the Site Manager and ECoW. In the event of a find, any

works which may cause further disturbance to the area will be ceased, the find will be

documented, photographed and preserved by the ECoW as per instructions in PAD (Appendix

9A). Advice will be sought from an archaeological consultant if required and reports made to

Historic Environment Scotland and The Highland Council.

Figure 9.1 Protocol for Archaeological Discovery

Discovery

A find is made during construction, in

grabs, spoil barge, or on cables/anchors.

Inform

Site Manager

ECoW

ECoW Actions

• Stop any works which could cause further disturbance to the area.

• Examine any equipment and materials coming up from the sea bed.

• Note occurrence in Site Day Book.

• Photograph any finds as per instructions in Appendix 9A.

• Preserve any finds as per instructions in Appendix 9A.

• Contact an Archaeological Consultant if required.

• Reports finds, and pass on all documentation and photographs.

ECoW Reports

• Historic Environment Scotland – 0131 668 8600

• Highland Council Archaeology – 01463 702503

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Invergordon Service Base Phase 4 Development

Appendix 9A – Protocol for Archaeological Discoveries

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Offshore Renewables

Protocol for Archaeological Discoveries

The reporting process

On land At sea

Discoveries found

in the intertidal zone

A find is made during

construction

Discoveries made

on board a vessel

A find is made on board

the vessel, in grabs or

attached to anchors

and cables

Discoveries found

after work on site

A find or anomaly is

discovered during sample

analysis or while reviewing

geophysical data

Discoveries found

on the seabed

An anomaly indicates

that an object or structure

has been encountered on

the seabed

Project Staff

Inform Site Champion

Report to

Nominated Contact

Handout 3: The reporting process

Site Champion

Avoid further disturbance work in this area

(if found during works)

Note the occurrence, in a daybook, or site log

Photograph any find(s) recovered (see Handout 4)

Arrange for any recovered find to be immersed in

seawater (if waterlogged) or in a suitable, clean,

covered container as appropriate (see Handout 5)

Inform the Nominated Contact and pass on all available

information, including a copy of the Preliminary Record

and copies of any photographs, drawings or data files

Site Champion

Cease work that may impact the seabed in that area,

or move to a new location

Examine any gear, such as grapnels or ploughs,

coming up from the seafloor

Note the occurrence in the vessel’s log

Mark the area on navigational/survey software

Photograph any find(s) recovered (see Handout 4)

Arrange for any recovered find to be immersed in

seawater (if waterlogged) or in a suitable, clean,

covered container as appropriate (see Handout 5)

Inform the Nominated Contact and pass on all available

information, including a copy of the Preliminary Record

and copies of any photographs, drawings or data files

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Offshore Renewables

Protocol for Archaeological Discoveries

Prehistoric finds

Handout 6: Prehistoric finds

Some of the first things that spring to mind

when you think of underwater archaeology are

shipwrecks and aircraft wrecks. Whilst shipwrecks

are important, there is a huge range of other

exciting and significant artefacts that can be

found under the sea.

Some of the most important finds from the seabed

are stone tools. Stone tools are the oldest known

technology used by man. These implements were

first used in Africa 2.5 million years ago and until

metal was discovered, stone was the primary

resource for making tools.

Whilst a large majority of tools are made

from flint, in places where this was not

available other stones were used instead.

It is not only the tools which are of interest to

archaeologists, flint-knapping produces piles of

waste flakes. Archaeologists examine the flakes

to see what sort of tools were being made.

See below for some examples of handaxes,

arrowheads and flakes.

How to recognise

stone tools and flakes

Stone tools and flakes have

recognisable features and

shapes that indicate they

were made by humans. The

negative flake scars and bulb

of percussion are some of

the easiest to find.

The bulb of percussion is

a curved raised lump left

behind when a flake is struck

off. The negative scar is a

concave cone-shaped scar on

the flake where it came off

the core - the opposite of the

bulb of percussion.

1

2

3

4

5

Negative Flake Scars

Ridges

Cortex

Bulb Scar

Butt

6

7

8

9

10

Point of Percussion

Cone of Percusion

Bulb of Percussion

Conical Ripples

Fissures

1

2

9

8

910

4 5 6 7

3

2

1

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Offshore Renewables

Protocol for Archaeological Discoveries

Metalwork and Concretions

Handout 7: Metalwork and Concretions

What is a concretion?

Concretions are dense clumps of hard material that

develop on the surface of iron or other ferrous

metals as they corrode. A concretion can form one

clump around an object or become large sections

on iron shipwrecks. Within a concretion the object

gradually corrodes away, sometimes leaving only a

hollow space. It is easy to see if a concretion has

been freshly pulled off an iron object as it has a

bright orange rust colour.

Why are concretions important?

Concretions can easily hide the shape of an object,

making them impossible to identify. However

you should not assume that concretions are

unimportant; x-rays can sometimes reveal what

lies underneath the concretion, or injecting filler

can make a mould of the hollow shape.

Recording

As with other types of artefacts, the more

information we have the better. When recording

concretions useful information includes length,

width, diameter and thickness of concretion,

where possible.

Keep your eyes peeled

Some people miss concretions as they can

look like rocks from the seafloor. If you find

something you’re not sure about, report it.

This x-ray and drawing shows a broken nail wrapped inside a metal sheet

Nail

Metal sheet

A concretion can look like a rock

UM

A

Nail

Metal sheet

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Offshore Renewables

Protocol for Archaeological Discoveries

Munitions and Ordnance

Handout 8: Munitions and Ordnance

Despite long periods spent underwater munitions

can still be extremely dangerous and should always

be treated with caution. The appropriate response

when dealing with munitions is to report them to

the police, coastguard or Ministry of Defence in

line with your company policy.

How common are munitions?

Up to 10% of the bombs that fell on and around

the UK during WWII failed to function and so

far only a fraction

of these have

been recovered.

In addition to these

‘blind’ munitions,

ordnance from both

world wars was

dumped at sea and

munitions on board

sunken vessels are

rarely salvaged.

Reporting munitions

Always follow safe working procedures when

dealing with munitions. Before reporting munitions

via the PAD they must be made safe or identified as

inert by the police or a military Explosive Ordnance

Disposal Officer (EOD). Once the items have been

confirmed as safe and suitable for handling they

should be reported as normal through the

protocol. If you have any queries regarding the

reporting of munitions please contact a member of

the Implementation Service team.

Always follow Company Guidelines on the

SAFE TREATMENT OF MUNITIONS

when they are discovered

Vis or Random pistol

Fuse cap

German WWII machine gun Ammunition

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Invergordon Service Base Phase 4 Development

Section 10 Page - 1

Construction Environmental Management Document

Section Number 10

Section Title Materials Management Plan

Issue 1

Issue Date 15/05/18

Author Jon Ashburner

Approved Fiona Henderson

Document History

Issue Date Reason for Change

1 15/05/18 Issued for Marine Licence Application

10.1 Introduction Due to the scale of the area being reclaimed there is a need for large volumes of material to

be utilised in the construction of Phase 4. Hence it is essential that they are appropriately

stored and managed. Once the Principal Contractor is appointed, a site map will be developed,

to determine appropriate storage locations for each material type, in accordance with industry

best practice and relevant environmental guidance. The site map will be approved by the

ECoW, and provided as Appendix 10A to the CEMD.

The transport of material by road is considered in the Framework Construction Traffic

Management Plan (FCTMP), as such they are not discussed in this section. Waste management

is discussed in Section 8.

10.2 Material Requirements The estimated quantities of the main materials associated with the construction of the Phase

4 project are provided below:

• Revetment materials (62,000m3) – rock to be delivered by road and positioned, hence it

will not require storage.

• Rock (23,000m3) for Rock armour – delivered by road.

• Stone fill for surfacing (12,000m3) – delivered by road.

• Piles (5,200 tonnes) – which will be delivered by sea to site and stored either on the

piling barge or in the laydown area until required.

• Infill material (320,000m3) – to be delivered by sea, discharged into the infill area and

moved into place.

• Concrete (3,500m3) – Local ready-mix supplier which is delivered by road.

• Fuel (81,600 gallons/370m3) – required for vehicle and plant.

• Miscellaneous inert materials – including furnishings, electrical cabling, drainage pipes

etc, delivered and stored on site till required.

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Invergordon Service Base Phase 4 Development

Section 10 Page - 2

• Miscellaneous hazardous materials – resins etc which will be delivered and stored in the

COSHH Storage area.

10.3 Fuel Storage Where fuel is stored and plant is fuelled the following will apply.

• The fuel point is to be sited at least 10m away from drains and watercourses.

• A suitable double skinned or bunded tank and stand will be provided.

• The fuel tank will be protected from accidental damage, collision or vandalism.

• The distribution hose will be fitted with a shut off type filling nozzle.

• The filling nozzle will be fitted with a security lock to prevent unauthorised use.

• A drip tray will be provided below the distribution hose and nozzle when not in use.

• A fuel accountancy system will be employed.

• Refuelling will be carried out in accordance with site procedures by trained personnel.

• Filling of the fuel store will be carried out in accordance with site procedures by trained

personnel.

10.4 Hazardous Material Storage All hazardous material will be stored in accordance with COSHH data in the COSHH storage

area. The COSHH store will be locked and access controlled, an inventory of materials stored

will be maintained.

10.5 Material Quality Materials will be sourced from reputable suppliers and will be subject to the appropriate

quality checks to ensure that it is fit for purpose.

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Invergordon Service Base Phase 4 Development

Appendix 10A – Site Map

NOT CURRENTLY USED:

To be developed in conjunction with the Principal Contractor once appointed

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Invergordon Service Base Phase 4 Development

Section 11 – Page 1

Construction Environmental Management Document

Section Number 11

Section Title Habitat and Species Protection Plan’s

Issue 1

Issue Date 15/05/18

Author Jon Ashburner, Lucy Quinn & Innes Beaton

Approved Fiona Henderson

Document History

Issue Date Reason for Change

1 15/05/18 Issued for Marine Licence Application.

Contents 11 Habitat and Species Protection Plans ................................................................................................. 2

11.1 Introduction ............................................................................................................................................. 2

11.2 Breeding Birds Species Protection Plan (BBSPP) ........................................................................ 3

11.3 Marine Mammal Species Protection Plan (MMSPP) ................................................................. 5

11.4 Diadromous Fish Species Protection Plan (DFSPP) ................................................................ 14

11.5 Otter Species Protection Plan (OSPP) ......................................................................................... 16

11.6 Marine Non-Native Species ............................................................................................................ 18

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Invergordon Service Base Phase 4 Development

Section 11 – Page 2

11 Habitat and Species Protection Plans

11.1 Introduction There are a number of ecologically designated areas in and around the Cromarty Firth as

detailed in Table 11.1.

Table 11.1 – List of Protected Areas

Designation Name Location relative to

Invergordon Description

Site of Special

Scientific Interest

(SSSI)

Cromarty Firth Adjacent Birds & Littoral

Sediment

Special Protection

Areas (SPA)Cromarty Firth Adjacent Birds

RAMSAR Cromarty Firth Adjacent Birds

Special Area of

Conservation (SAC) Moray Firth 5km East

Sub-tidal

sandbanks &

marine mammals

Proposed Special

Protection Area

(pSPA)

Moray Firth 10km East Birds

Special Area of

Conservation (SAC)

Dornoch Firth

& Morrich

More

20km North East Marine mammals

& seals

Habitat and Species Protection Plans have been identified for breeding birds, marine

mammals, diadromous fish and, otters to ensure that all concerned are aware of the specific

issues associated with the species of concern. All mitigation is included within Section 14:

Schedule of Mitigation, to aid implementation within the CEMPs detailed in Section 6.

In addition to the protection of specific species, the management of Marine Non-Native

Species has been included in Section 11.6.

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Invergordon Service Base Phase 4 Development

Section 11 – Page 3

11.2 Breeding Birds Species Protection Plan (BBSPP)

11.2.1 Introduction The Phase 4 construction site is immediately adjacent to the Cromarty Firth Special Site of

Scientific Interest (SSSI) and Special Protection Area (SPA), designated for their non-breeding

and breeding birds (11.1).

A number of bird species have the potential to be affected by construction activities. During

the rock armour removal, it is possible that breeding birds may be using the rock armour for

nesting habitat or may be in the close vicinity to where construction vehicles will have to be.

The species most likely to be using the rock revetment will be eider ducks, but it is possible

other species may use the rock revetment, such as Arctic or common terns, oyster catchers, or

common gulls. To avoid the accidental destruction of any nests, mitigation is required to

protect the bird species.

11.2.2 Protection All wild birds in the UK are protected under the Wildlife and Countryside Act 1981 (as

amended). Directive 2009/147/EC of the European Parliament and of the Council, on the

conservation of wild birds, commonly known as the Birds Directive, protects all wild birds, their

nests, eggs and habitats within the European Community. It gives member states of the

European Union, the power and responsibility to classify Special Protection Areas (SPAs), to

protect birds which are rare or vulnerable in Europe, as well as all migratory birds which are

regular visitors. The 2009 Directive is the consolidated (or 'codified') version of Council

Directive 79/409/EEC which originally came into force in 1979 and was amended many times

before being replaced by the current version. The level of protection for the likely species are

shown below.

Eiders and common terns are designated species under the Cromarty Firth SPA. Both Arctic

and common terns are Annex 1 species on the Birds Directive.

11.2.3 Offences It is an offence to intentionally or recklessly:

• Kill, injure or take a wild bird;

• Take, damage, destroy or interfere with a nest of any wild bird whilst it is in use or

being built (or at any time for a nest habitually used by any bird listed in Schedule A1;

• Obstruct or prevent any wild bird from using its nest;

• Take or destroy an egg of any wild bird;

• Disturb any wild bird listed on Schedule 1 whilst it is building a nest or is in, on, or near

a nest containing eggs or young, or whilst lekking (undertaking mating rituals);

• Disturb the dependent young of any wild bird listed on Schedule 1; and harass any wild

bird listed on Schedule 1A.

It is also an offence to possess or control a live or dead wild bird, an egg of a wild bird (or any

such derivatives), or to knowingly cause or permit any of the above acts to be carried out.

There are additional offences in relation to use of prohibited methods of killing or taking wild

birds, for the sale of live and dead wild birds (listed on Schedule 3) and for registration and

keeping of captive wild birds (Schedule 4). There are a number of exceptions to these offences

including shooting outside of the closed season for certain species (on Schedule 2).

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Invergordon Service Base Phase 4 Development

Section 11 – Page 4

11.2.4 Mitigation

11.2.4.1 Pre-construction surveys

Pre-construction surveys will take place for breeding birds before any rock armour on the west

side of Phase 3 is removed. The pre-construction surveys must take place no more than 48

hours before the rock armour removal is due to take place.

11.2.4.2 Fencing

Once the rock revetment has been removed, if it needs to be stockpiled during the bird

breeding season (March – August) then suitable fencing will be placed around the pile to

dissuade eiders from nesting amongst the rocks. It should be noted that no form of netting is

to be used directly on top of the rocks themselves, as this can entrap birds.

11.2.4.3 Construction timings

It will not be possible to schedule all disturbing works to occur outside the breeding season.

However, construction activities will aim to start outside the most sensitive months of the

breeding season (i.e. between September-March). Ideally, the rock armour removal would

occur out with the bird breeding season (i.e. outwith March-August).

11.2.4.4 Light regime

Lights will be required to facilitate construction work during hours of darkness and provide a

safe environment for site personnel. Lighting will be directional and local to works, as such it

is not predicted to impact upon birds utilising the intertidal area north and west of the

construction area. Lights will be switched off when not in use.

11.2.4.5 ECoW

The ECoW will ensure that the breeding bird protection plan is implemented and reviewed

throughout the construction process.

11.2.5 Survey and Monitoring As mentioned in Section 11.2.4.1 pre-construction surveys will take place prior to the rock

armour removal. During construction there will be ongoing activities which would disturb birds

and hence deter them from nesting however, the ECoW will have a watching brief for nesting

birds during the breeding season, particularly in peak breeding season (April to July).

In event of a nest being found, in the first instance an avoidance area will be de-marked to

prevent damage to the nest. The specific buffer zone required will depend on the species, and

will be decided by a suitably qualified ecology, however it is expected to be a minimum of 5m.

Where for construction or safety reasons it is not practicable to continue to avoid the area for

the duration of the nesting season; then RSPB and SNH will be contacted for advice.

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Invergordon Service Base Phase 4 Development

Section 11 – Page 5

11.3 Marine Mammal Species Protection Plan (MMSPP)

11.3.1 Introduction Evidence suggests that common seals, harbour porpoises and bottlenose dolphins are resident

within the zone of influence associated with the Phase 4 Development area. These species will

also be present in the vicinity of the Sutors spoil ground, along with minke whales and grey

seals which are considered occasional visitors. The spoil ground is located within the Moray

Firth SAC, which is in part designated for bottlenose dolphins.

Marine Mammals can be affected by changes in water quality, disturbance and injury from

underwater noise, and physical injury though interactions with spoil disposal operations.

Water quality will be managed through the CEMPs (Section 6), aligned to the schedule of

mitigation (Section 14) and as such is not considered further in this section.

11.3.2 Protection Whales and dolphins are classed as European Protected Species (EPS) and are fully protected

under the Conservation (Natural Habitats, &c.) Regulations 1994 (as amended).

The main legislation with regard the protection of seals is The Marine (Scotland) Act 2010,

which provides for Scottish Ministers to designate ‘seal conservation areas’.

Common seals using the Cromarty Firth also afforded protection under the Conservation

(Natural Habitats, &c.) Regulations 1994, due to connectivity with the Dornoch Firth and

Morrich More SACs.

11.3.3 Offences The following provides a summary of the offences in the Conservation (Natural Habitats, &c.)

Regulations 1994 (as amended) in relation to whales, dolphins and porpoises in Scottish

territorial waters (within 12 nautical miles of land). It is an offence to intentionally or recklessly:

• Kill, injure or capture whales, dolphins or porpoises; and

• Disturb or harass them.

On the 1st February 2011 it became an offence to intentionally or recklessly kill, injure or take

a seal at any time of year, except to alleviate suffering or where a licence has been issued to

do so by Marine Scotland under the Marine (Scotland) Act 2010. Under the Marine (Scotland)

Act 2010 it is also an offence to intentionally or recklessly harass seals at significant haul-out

sites. The Conservation (Natural Habitats, &c.) Regulations 1994 (as amended) prohibits

certain methods of catching or killing seals.

11.3.4 Mitigation

During construction a number of noisy activities will be undertaken the most notable of which

is piling, which has the potential to cause injury and disturbance to marine mammals. As such

a Piling Marine Mammal Protocol has been developed, to reduce the risk of injury to marine

mammals (Section 11.3.4.1).

There is also the potential for marine mammals to be injured through interactions with falling

debris during dredged spoil disposal operations. In order to mitigate this a Spoil Disposal

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Marine Mammal Protocol has been developed, to reduce the risk of a marine mammal being

underneath the disposal vessel when the spoil is released (Section 11.3.4.2).

11.3.4.1 Piling Marine Mammal Protocol General Provisions

All marine mammal observers (MMOs) and passive acoustic monitoring (PAM) technicians will

be trained to Joint Nature Conservation Committee (JNCC) standards. Both MMOs and PAM

technicians shall have the power to delay piling operations should marine mammals be present

in the mitigation zone. The mitigation zone for piling operations shall extend 500m from the

piling barge.

A formal log shall be maintained by the MMOs and PAM technicians whether marine mammals

are present or not. The forms used will be the standard JNCC MMO forms, modified to suit

piling driving operations (Appendix 11A). Paper forms should be provided to the ECoW for

collation on a regular basis. All data will be stored electronically and provided to Marine

Scotland at the end of the dredging campaign. The details recorded will include but are not

limited to:

• Time and location of the disposal operations;

• Mobilisation and demobilisation times of MMO/PAM team;

• Start time of piling;

• Duration of piling;

• Breaks in operations, or times spent at reduced hammer energy;

• Conditions affecting observations including sea state and visibility, throughout

surveillance;

• Records of any sightings/ acoustic detections and actions taken;

• Records will also be kept of sightings of other marine species including otters.

Visual MMO watches will be conducted during daylight hours, when sea state is ≤3, and when

visibility permits (clear visibility ≥600m). Unless PAM is available, piling operations will not

take place during hours of darkness, or if conditions are unsuitable for visual observations.

If available, PAM will be used during hours of darkness, when sea state is ≥4, or if visibility

prohibits visual observation. Summaries of both visual and acoustic observation protocols are

provided below.

Visual Observation Protocols

Visual marine mammal observations will be conducted by an MMO at a set onshore

observation post, providing good visibility of the mitigation zone. The observation post will

be elevated, in order to maximise marine mammal detection probability:

1. The MMO should be informed by the site manager or piling foreman of proposed

piling start times as soon as possible (at least 1hours notice), or the night before for a

morning start.

2. The MMO will commence the watch using binoculars (minimum characteristics of 8x42)

so that at least a 30-minute watch has been conducted prior to the anticipated start

time. The MMO should focus their effort on the mitigation zone and advise the site

piling foreman if marine mammals are present.

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3. If the 500m mitigation zone remains clear of marine mammals during the watch, the

MMO will give permission to commence piling.

• If animals are sighted in the zone the MMO will track the animals visually, and

the start will be delayed until the zone has been clear for 20min. The MMO will

keep the site team up to date with progress.

4. Once piling has commenced, the MMO should be notified. The MMO does not need

to continue watching. If marine mammals are observed during piling operations, details

should be noted on a recording form.

• There is no requirement to stop works for marine mammals entering the zone

once piling has commenced, provided piling is continuous.

• Continuous is defined as without a break in operations exceeding 10min in

duration.

5. The MMO should be notified of any planned breaks in piling which may exceed 10min

in duration, in order to minimise restart time:

• If a break is greater than 10min in duration, a full 30min pre-watch followed by

a 20min soft start will be required, unless an MMO is on watch for the duration

of the break.

• If MMO cover is in place, and the mitigation zone remains clear of marine

mammals for the entirety of a break up to 30min in duration, piling can

recommence at full power with permission from the MMO.

• If animals are present within the mitigation zone during a break exceeding

10min in duration, then the restart will be delayed by the MMO until the zone

is clear for 20min.

• If the break in operations exceeds 30min, a 30min pre-watch (observations

conducted during the down time will be included) is required before piling can

recommence.

6. Visibility Limits:

• Must have clear visibility to ≥600m, sufficient light (i.e. daylight hours) and sea

state must be ≤3.

A simple flow chart summarising the visual MMO protocols is provided in Figure 11.1.

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Figure 11.1. Flowchart of piling MMO protocol.

Acoustic Monitoring Protocols

During hours of darkness, sea states ≥4, or if visibility falls to below 600m, marine mammal

detection will be conducted acoustically using Passive Acoustic Monitoring (PAM). This system

will be able to detect vocalising harbour porpoises to a range of up to 300m and bottlenose

dolphins to a range of up to 2km. The PAM system will be deployed in a location where the

detection ranges outlined above provide sufficient coverage of the piling mitigation zone,

allowing detection of vocalising cetaceans in the area. The following protocol will be used for

PAM:

1. The PAM operator should be informed by the site manager or piling foreman of

proposed piling start times as soon as possible (at least 1hours notice), or the night

before for a morning start.

2. The PAM operator will commence the watch using so that at least a 30-minute watch

has been conducted prior to the anticipated start time. The PAM operator should

advise the site piling foreman if marine mammals are present.

3. If the not marine mammal detections are made within the 500m mitigation zone, the

MMO will give permission to commence piling.

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• If animals are detected in the zone the PAM operator will continue to monitor,

and the start will be delayed until the zone has been clear for 20min. The PAM

operator will keep the site team up to date with progress.

4. Once piling has commenced, the PAM operator should be notified. The PAM watch

does not need to continue. If marine mammals are detected during piling operations,

details should be noted on a recording form.

• There is no requirement to stop works for marine mammals entering the zone

once piling has commenced, provided piling is continuous.

• Continuous is defined as without a break in operations exceeding 10min in

duration.

5. The PAM operator should be notified of any planned breaks in piling which may exceed

10min in duration, in order to minimise restart time:

• If a break is greater than 10min in duration, a full 30min pre-watch followed by

a 20min soft start will be required, unless a PAM watch is conducted for the

duration of the break.

• If a PAM watch is conducted, and the mitigation zone remains clear of marine

mammals for the entirety of a break up to 30min in duration, piling can

recommence at full power with permission from the PAM operator.

• If animals are present within the mitigation zone during a break exceeding

10min in duration, then the restart will be delayed by the PAM operator until

the zone is clear for 20min.

• If the break in operations exceeds 30min, a 30min pre-watch (PAM watches

conducted during the down time will be included) is required before piling can

recommence.

A simple flow chart summarising the acoustic piling protocols is provided in Figure 11.2.

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Figure 11.2. Flowchart of piling PAM protocol.

11.3.4.2 Spoil Disposal Marine Mammal Protocol General Provisions

All marine mammal observers (MMOs) and passive acoustic monitoring (PAM) technicians will

be trained to Joint Nature Conservation Committee (JNCC) standards. Both MMOs and PAM

technicians shall have the power to delay disposals should marine mammals be present in the

mitigation zone. The mitigation zone for spoil disposals shall extend 200m from the disposal

vessel.

A formal log shall be maintained by the MMOs and PAM technicians whether marine mammals

are present or not. The forms used will be the standard JNCC MMO forms, modified to suit

spoil disposal operations (Appendix 11B). Paper forms should be provided to the ECoW for

collation on a regular basis. All data will be stored electronically and provided to Marine

Scotland at the end of the dredging campaign. The details recorded will include but are not

limited to:

• Time and location of the disposal operations;

• Mobilisation and demobilisation times of MMO/PAM team;

• Start time of disposal;

• Duration of disposal;

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• Conditions affecting observations including sea state and visibility, throughout

surveillance;

• Records of any sightings/ acoustic detections and actions taken;

• Records will also be kept of sightings of other marine species including otters.

Visual MMO watches will be conducted during daylight hours, when sea state is ≤3, and when

visibility permits (clear visibility past the spoil ground for land-based observations, and ≥300m

for vessel based). Unless PAM is available, spoil disposal operations will not take place during

hours of darkness, or if conditions are unsuitable for visual observations.

If available, PAM will be used during hours of darkness, when sea state is ≥4, or if visibility

prohibits visual observation. Summaries of both visual and acoustic observation protocols are

provided below.

It is vital that sufficient advance notice is provided for MMO call out, to allow for early check

on sea state and visibility at the Spoil Ground, so that PAM operators may be called out in time

to conduct 30-minute PAM survey prior to vessel arrival at the Spoil Ground if conditions

require.

Visual Observation Protocols

Visual marine mammal observations will generally be conducted by an MMO at set

observation locations at either North or South Sutor. Directions to the shore observation

points are found in Appendix 11C. The MMO may also be based on the disposal vessel or

separate observation vessel if required. The following protocol will be followed regardless of

the MMO location:

1. The MMO should be informed by the dredger via VHF radio or phone once dredging

is complete and that the ship is en route to the spoil ground. The vessel must give

suitable warning to the MMO observer to allow them to get into position and start a

watch at least 20 minutes before the anticipated arrival time.

2. The MMO will commence the watch using binoculars (minimum characteristics of 8x42)

so that at least a 20-minute watch has been conducted by the time the ship reaches

the spoil ground. The MMO should focus their effort on the spoil ground and advise

the ship if marine mammals are present in order to avoid them if possible.

3. Once in the spoil ground the ships officers will ask the MMO if they are clear to

commence the disposal. If the 200m mitigation zone is clear, then MMO will give

permission to proceed. If marine mammals are present within the mitigation zone,

disposal will be delayed until the marine mammals have left the mitigation zone and 5

minutes have passed since an animal was last sighted within the zone.

4. Visibility Limits:

• Shore based – Must have clear visibility past the Spoil Ground, sufficient light

(i.e. daylight hours), and sea state must be ≤3.

• Vessel based – Must have clear visibility to 300m from the disposal vessel,

sufficient light (i.e. daylight hours) and sea state must be ≤3.

A simple flow chart summarising the daytime MMO protocols is provided in Figure 11.3.

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Figure 11.3. Flowchart of spoil disposal MMO protocol.

Acoustic Monitoring Protocols

During hours of darkness, sea states ≥4, or if visibility falls to below 300m for vessel-based

observation or visibility is not clear past the spoil ground for shore-based observation, marine

mammal detection will be conducted acoustically using Passive Acoustic Monitoring (PAM).

This system will be able to detect vocalising harbour porpoises to a range of up to 300m and

bottlenose dolphins to a range of up to 2km. The PAM system will be deployed in a location

where the detection ranges outlined above provide sufficient coverage of the spoil ground to

allow detection of vocalising cetaceans in the area. The following protocol will be used for

PAM:

1. The PAM technician shall be given a minimum warning of 60 minutes ahead of the

intended disposal time, in order to prepare for the watch. VHF radio or phone contact

will inform the PAM operator when the vessel is en route. The operator will work from

the PAM base station where the laptop will receive the signal from the PAM buoy.

2. The PAM technician should perform a minimum of a 30-minute watch before the vessel

reaches the Spoil Ground.

3. Once the PAM technician is satisfied no marine mammals are present within the 200m

mitigation zone, they may advise the crew to commence the disposal. If mammals are

detected within the zone, the disposal will be delayed until 10 minutes have passed

since last detection within the zone.

A simple flow chart summarising the PAM protocols is provided in Figure 11.4.

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Figure 11.4. Flowchart of spoil disposal PAM protocol.

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11.4 Diadromous Fish Species Protection Plan (DFSPP)

11.4.1 Introduction Diadromous fish migrate/emigrate past the site and could be disturbed or injured by changes

in water quality. The EIAR identified that the most sensitive period with regards to diadromous

fish is the Atlantic salmon outward smolt run. Disturbance of this migration event has the

potential to result in significant impacts on the species. Migrating salmon smolt are considered

to be very sensitive to increased sediment loading in the water column, and as such dredging

or dredged spoil disposal operations have the potential to interrupt the outward smolt run.

It has been identified that the Atlantic salmon outward smolt run occurs between later April,

and early June, with a peak in May.

11.4.2 Protection Council Directive 92/43/EEC on the conservation of natural habitats and of wild fauna and

flora, known as the ‘Habitats Directive’ was adopted in 1992. The Directive is the means by

which the European Union meets its obligations under the Bern Convention.

Species listed in Annex II of the Habitats Directive, which are native to the UK should be

conserved through the designation of Special Areas of Conservation (SACs). Atlantic salmon

(Salmo salar) present in UK waters are listed in Annexe II. Since 1994 all SACs, in combination

with Special Protection Areas (SPAs), comprise the UK contribution to the Natura 2000

ecological network of protected sites.

Atlantic salmon are also listed in Annex V of the Habitats Directive. As such they are defined

as a species of community interest. Therefore, taking in the wild may be subject to

management measures.

The UK Biodiversity Action Plan (UKBAP) lists priority species and habitats, which have been

identified as the most threatened and requiring conservation action under the plan. Numerous

diadromous fish species are included in the list of UKBAP priority species, including:

• The multi-sea winter component of the Atlantic salmon population;

• Sea trout (brown trout) (Salmo trutta); and

• European eel.

11.4.3 Offences The Salmon and Freshwater Fisheries Act 1975 makes it an offence to knowingly take, kill or

injure, or attempt to take, kill or injure, any salmon, trout or freshwater fish, which is unclean

or immature. The Act also makes it an offence to cause or knowingly permit to flow, or put or

knowingly permit to be put, into any waters containing fish or into any tributaries of waters

containing fish, any liquid or solid matter to such an extent as to cause the waters to be

poisonous or injurious to fish or the spawning grounds, spawn or food of fish.

11.4.4 Mitigation Mitigation with regard to minimising disruption of the Atlantic salmon outward smolt run is

provided below.

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11.4.4.1 Sensitive Timing of Activities

In order to minimise potential impacts on diadromous fish from the construction of the Phase

4 Development, no dredging or dredged spoil disposal operations will be conducted from the

1st to the 31st May (inclusive) during any year. This avoids the peak outward smolt migration.

11.4.4.2 Environmental Clerk of Works

An ECoW will be appointed to oversee and ensure environmental best practice and mitigation

strategies to minimise degradation of water quality resulting from increased sediment loading

of the water column, associated to dredging and dredge spoil disposal operations. The ECoW

will have the power to stop works if required till appropriate investigations or/and action are

taken.

11.4.5 Monitoring The ECoW will remain vigilant for dead diadromous fish in the vicinity of the working areas

during the construction of the Phase 4 Development. Any signs of mass mortality will be

reported to Marine Scotland and SNH.

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11.5 Otter Species Protection Plan (OSPP)

11.5.1 Introduction A Post construction Survey of the Phase 3 Development was carried out during September

2016 to inform the baseline for the Phase 4 EIA. This included the Queen’s Dock, Phase 3 and

up to 1km west of the Invergordon Service Base along the shore (Provided in Appendix M.1)

[Affric Limited, 2016].

11.5.2 Protection Otters are classed as EPS and are fully protected under the Conservation (Natural Habitats,

&c.) Regulations 1994 (as amended). This lists a number of offences in relation to otters and

the places in which they live.

11.5.3 Offences The under the Conservation (Natural Habitats, &c.) Regulations 1994 (as amended) in

relation to wild otters, it is an offence to deliberately or recklessly:

• Capture, injure or kill an otter;

• Harass an otter or group of otters;

• Disturb an otter in a holt or any other structure or place it uses for shelter or

protection;

• Disturb an otter while it is rearing or otherwise caring for its young;

• Obstruct access to a holt or other structure or place otters use for shelter or

protection or to otherwise deny the animal use of that place;

• Disturb an otter in a manner that is, or in circumstances which are, likely to

significantly affect the local distribution or abundance of the species; and

• Disturb an otter in a manner that is, or in circumstances which are, likely to impair its

ability to survive, breed or reproduce, or rear or otherwise care for its young.

It is also an offence to:

• damage or destroy a breeding site or resting place of such an animal (note that this

does not need to be deliberate or reckless to constitute an offence); and

• keep, transport, sell or exchange or offer for sale or exchange any wild otter or any

part or derivative of one (if obtained after 10 June 1994).

11.5.4 Mitigation To mitigate against the potential to damage holts or layups the following mitigation will be

implemented. Prior to construction works being undertaken a pre-construction otter survey

will be carried out to understand the current activity levels in the area and potential for holts

and layups within 200m of the construction site. Prior to the installation of fenders on Berth 5

a further survey will be carried out and thereafter if required discussed with Scottish Natural

Heritage (SNH). These surveys will inform the need for additional surveys (camera trapping)

and the development of additional mitigation. An EPS licence will be applied for if required,

depending on the outcome of the surveys.

Immediately prior to rock armour being removed it will be visually checked to ensure that

otters are not present. Rock armour will only be removed on the agreement of the ECoW.

There may be some flexibility in the construction programme as to when the rock armour is

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removed, hence if a natal holt is found during the surveys or visual checks, works will be

delayed until an appropriate way forward has been agreed with SNH.

Mitigation identified in the CEMPs (Section 6) with regard to water quality should be

implemented to protect otters from a release of hazardous substances.

11.5.5 Monitoring

The ECoW will remain vigilant for otters in the vicinity of the working areas during the

construction of the Phase 4 Development. Furthermore, the workforce shall be informed

through toolbox talks on to recognise and report sightings of otters. Any otter mortality will

be reported to SNH.

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11.6 Marine Non-Native Species

11.6.1 Introduction The consequences of introducing non-native species into the local marine ecosystem include;

• Damage or displacement of indigenous species;

• Disruption of sensitive ecosystem balance;

• The spread of foreign diseases which severely affect native species;

• Interference with river processes with potential of increased flood/drought potential;

• Damage to buildings and marine infrastructure; and

• Significant economic costs associated with the control and management of invasive

species.

11.6.2 Mitigation All works will be carried out in accordance with The Code of Practice on Non-Native Species

(approved by Scottish Parliament 28 June 2012), adopting a precautionary approach to

minimise the risk of releasing non-native species, using risk assessments relevant to planned

activities and seeking advice on best practice whenever necessary, including reporting the

presence of non-native species.

The following guidance will be adopted during the Phase 4 Development works to minimise

the risks of introducing Marine Non-Native Species (MNNS) into the Cromarty Firth during any

in water works and/or barge landing activities.

The implementation of this guidance will be facilitated during induction, Toolbox Talks, the

weekly environmental checklist and internal Environmental & Quality audits.

Appropriate planning should help prevent the introduction of MNNS. This will include

• All equipment is to be received at ‘as new’ standard;

• Local vessels within biogeographic boundaries will be utilised wherever possible i.e.

within the North Sea ecosystem; and

• All vessels will be International Maritime Organisation (IMO) compliant, including the

Ballast Water Management Convention.

For road transportable boats, plant and equipment, the following mitigation techniques will

be employed as applicable;

• Salt water will be drained from every part of the plant, or boat and any other equipment

that transport water from the marine environment, prior to being mobilised to site or

demobilised from it;

• All parts of plant, equipment or boats that come into contact with the water will be

thoroughly cleaned before being mobilised to or demobilised from the Phase 4

Development. Removing any visible plant, fish, animal matter and soils;

• Dispose of any plant and animal materials in a secure and suitable bin or skip;

• Ensure hulls are cleaned regularly to avoid the risk of transporting MNNS and apply

adequate anti-fouling where appropriate.

• Avoid travelling through marine plants and weed where possible. If organic matter

becomes entangled in tracks, propellers etc; MNNS can be transferred to others areas.

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In event that invasive species are suspected the relevant authorities will be contacted by the

ECoW or PoCF Project Manager.

• SEARS (Scottish Environment & Rural Services): (08452) 302050

• SNH: [email protected]

• Marine Scotland: [email protected] - 01224 876544

• SEPA: http://www.sepa.org.uk/about_us/contacting_sepa.aspx

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Appendix 11A – Piling Marine Mammal Observation Forms

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PILING OPERATIONS

MMO Paper Forms – Piling Obs

MARINE MAMMAL RECORDING FORM - OPERATIONS

Regulatory reference number: Ship/ platform name:

Complete this form every time piling (vibro and impact) operations commences or ends. Times should be in UTC, using the 24-hour clock.

Date Activity Type pv = vibro piling pi = impact piling

Time soft start/ ramp-up began

Start Time of full power

Time of reduced output (if relevant)

Time Activity Stopped

Time pre-activity search began

Time search ended

Time PAM observation began

Time PAM observation ended

Was any mitigating action required? (yes/ no)

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PILING OPERATIONS

MMO Paper Forms – Piling Obs

MARINE MAMMAL RECORDING FORM - EFFORT Regulatory reference number: Ship/ platform name:

Record the following for all watches, even if no marine mammals are seen. START A NEW LINE IF SOURCE ACTIVITY OR WEATHER CHANGES. ENTER DATA AT LEAST EVERY HOUR. Date Visual

watch or PAM

(v/ p)

Observer's/ operator's name(s)

Time of start of section of watch

(UTC, 24hr clock)

Time of end of section of watch

(UTC, 24hr clock)

Activity Type

(pv /pi)

Activity level

(f/ s/ r/ n/ v)

Position (latitude and longitude)

Depth (m)

Wind dir’n

Wind force (B’fort scale)

Sea state

(g/ s/ c/ r)

Swell

(o/ m/ l)

Vis. (visual watch only)

(p/ m/ g)

Sun glare (visual watch only)

(n/ wf/ sf/ vf/ wb/ sb/ vb)

Precip.

(n/ l/ m/ h/ s)

Visual watch or PAM: v = visual watch; p = PAM Activity type: pi = impact piling, pv = vibro piling Activity level: f = full power; s = soft start; r = reduced power (not soft start); n = not active; v = variable (e.g. tests)

Sea state: g = glassy (like mirror); s = slight (no/ few white caps); c = choppy (many white caps); r = rough (big waves, foam, spray) Swell: o = low (< 2 m); m = medium (2-4 m); l = large (> 4 m)

Visibility: p = poor (< 1 km); m = moderate (1-5 km); g = good (> 5 km) Sun glare: n = none; wf = weak forward; sf = strong forward; vf = variable forward; wb = weak behind; sb = strong behind; vb = variable behind

Precipitation: n = none; l = light rain; m = moderate rain; h = heavy rain; s = snow

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PILING OPERATIONS

MMO Paper Forms – Piling Obs

MARINE MAMMAL RECORDING FORM - SIGHTINGS Regulatory reference number Ship/ platform name Sighting number

(start at 1 for first sighting of survey)

Acoustic detection number (start at 500 for first detection of survey)

Date: Time at start of encounter (UTC, 24hr clock)

Time at end of encounter (UTC, 24hr clock)

Were animals detected visually and/ or acoustically?

visual acoustic both

How were the animals first detected?

visually detected by observer keeping a continuous watch visually spotted incidentally by observer or someone else acoustically detected by PAM both visually and acoustically before operators/ observers informed each other

Observer's/ operator's name Position (latitude and longitude) Water depth (metres)

Species/ species group Description (include features such as overall size; shape of head; colour and pattern; size, shape and position of dorsal fin; height, direction and shape of blow; characteristics of whistles/ clicks)

Bearing to animal (when first seen or heard) (bearing from true north)

Range to animal (when first seen or heard) (metres)

Total number Number of adults(visual sightings only)

Number of juveniles(visual sightings only)

Number of calves(visual sightings only)

Photograph taken

yes no

Behaviour (visual sightings only)

Direction of travel (relative to site)

towards source variable away from source milling crossing perpendicular stationary (in channel swimming E↔W) other unknown

Direction of travel (compass points)

N W NE NW E variable SE stationary S unknown SW

Activity Type (pi, pv):

Activity level when animals first detected

full power not active soft start reduced power (other

than soft start)

Activity level when animals last detected

full power not active soft start reduced power (other

than soft start)

Time animals entered 500m mitigation zone (UTC, 24hr clock)

Time animals left 500m mitigation zone (UTC, 24hr clock)

Closest distance of animals from source activity (metres)

Time of closest approach (UTC, 24hr clock)

If seen during soft start give:

First distance

Closest distance

Last distance

during soft start (metres)

What action was taken?(according to requirements of guidelines/ regulations in country concerned)

none required delay start shut-down of active source power-down of active source power-down then shut-down

of active source

Length of power-down and/ or shut-down (if relevant) (length of time until subsequent soft start, in minutes)

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Appendix 11B – Spoil Disposal Marine Mammal Observation Forms

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SPOIL DISPOSAL OPERATIONS

MMO Paper Forms – Spoil Disposal Obs

MARINE MAMMAL RECORDING FORM - OPERATIONS

Regulatory reference number Ship/ platform nameComplete this form every time dredging, piling (vibro and impact), revetment removal or revetment construction commences/ends.Times should be in UTC, using the 24-hour clock.

Date Activity Type Time Disposal Start

Time Disposal End

Time pre-disposal search began

Time search ended Was any mitigating action required? (yes/ no)

Dredge Disposal

Dredge Disposal

Dredge Disposal

Dredge Disposal

Dredge Disposal

Dredge Disposal

Dredge Disposal

Dredge Disposal

Dredge Disposal

Dredge Disposal

Dredge Disposal

Dredge Disposal

Dredge Disposal

Dredge Disposal

Dredge Disposal

Dredge Disposal

Dredge Disposal

Dredge Disposal

Dredge Disposal

Dredge Disposal

Dredge Disposal

Dredge Disposal

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SPOIL DISPOSAL OPERATIONS

MMO Paper Forms – Spoil Disposal Obs

Regulatory reference number Ship/ platform nameRecord the following for all watches, even if no marine mammals are seen. START A NEW LINE IF DISPOSAL ACTIVITY OR WEATHER CHANGES. ENTER DATA AT LEAST EVERY HOUR. Date Observer's name(s) Time of

start of section of watch (UTC, 24hr clock)

Time of end of section of watch (UTC, 24hr clock)

Activity Type

Disposal in Progress (Y/N)

Start Position (latitude and longitude)

Start Depth (m)

End Position(latitude and longitude)

End Depth (m)

Vessel Speed (knots)

Wind dir’n

Wind force (B’fort scale)

Sea state (g/ s/ c/ r)

Swell

(o/ m/ l)

Vis. (visual watch only)

(p/ m/ g)

Sun glare (visual watch only)

(n/ wf/ sf/ vf/ wb/ sb/ vb)

Precip.

(n/ l/ m/ h/ s)

Dredge disposal

Dredge disposal

Dredge disposal

Dredge disposal

Dredge disposal

Dredge disposal

Dredge disposal

Dredge disposal

Dredge disposal

Dredge disposal

Dredge disposal

Dredge disposal

Dredge disposal

Sea state: g = glassy (like mirror); s = slight (no/ few white caps); c = choppy (many white caps); r = rough (big waves, foam, spray) Swell: o = low (< 2 m); m = medium (2-4 m); l = large (> 4 m)

Visibility: p = poor (< 1 km); m = moderate (1-5 km); g = good (> 5 km) Sun glare: n = none; wf = weak forward; sf = strong forward; vf = variable forward; wb = weak behind; sb = strong behind; vb = variable behind

Precipitation: n = none; l = light rain; m = moderate rain; h = heavy rain; s = snow

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SPOIL DISPOSAL OPERATIONS

MMO Paper Forms – Spoil Disposal Obs

MARINE MAMMAL RECORDING FORM - SIGHTINGS

Regulatory reference number Ship/ platform name Sighting number(start at 1 for first sighting of survey)

Date: Time at start of encounter (UTC, 24hr clock)

Time at end of encounter (UTC, 24hr clock)

How were animals detected?

Visually Acoustically Both

How were the animals first detected?

visually detected by observer keeping a continuous watch visually spotted incidentally by observer or someone else acoustically detected by PAM detected both visually and acoustically before MMO/PAM warned each other.

Observer's name Position (latitude and longitude) Water depth (metres)

Species/ species group Description (include features such as overall size; shape of head; colour and pattern; size, shape and position of dorsal fin; height, direction and shape of blow)

Bearing to animal (when first seen bearing from true north)

Range to animal(when first seen metres)

Total number Number of adults Number of juveniles Number of calves Photograph taken

yes no

Behaviour

Direction of travel (relative to vessel)

towards ship variable away from ship milling parallel to ship in same direction as ship stationary parallel to opposite direction to ship other crossing perpendicular ahead of ship unknown

Direction of travel (ANIMAL) (compass points)

N W NE NW E variable SE stationary S unknown SW

Activity Type: Dredging Disposal

Was the barge disposing when animals first seen?

Y N

Was the barge disposing when animals last seen?

Y N

Time animals entered 200m mitigation zone (UTC, 24hr clock)

Time animals left 200m mitigation zone (UTC, 24hr clock)

Closest distance of animals from vessel (metres)

Time of closest approach (UTC, 24hr clock)

What action was taken?(according to requirements of guidelines/ regulations in country concerned)

None required Delay disposal

Length of delay in disposal? (if relevant) (length of time until subsequent disposal)

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Appendix 11C – Spoil Disposal MMO Lookout Locations

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MMO Observation from South Sutor: 5 minute walk from the top South Sutor carpark.

1. Park in the carpark at the top of the South Sutor.

2. Take the path, signposted ‘Cromarty’

3. Walk approx. 300m down the hill until you

reach this bench.

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4. This is the MMO viewpoint.

5. Map of the viewpoint bench for MMO observation (marked X).

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MMO NORTH SUTOR OBSERVATION POINT: ~1.8km, ~20min walk from bottom to top.

1. Take the road to NIGG, before you reach the Nigg Ferry

terminal roundabout, you’ll see a LEFT-HAND TURN

with this signage.

2. Carry along this road for a short while, but it will soon

turn into a Private road so PARK somewhere near the

bottom of the road, there are some wide bays to do so.

3. As you walk part way up the hill, you will see a signpost for the CASTLECRAIG CIRCULAR PATH on

your RIGHT. CROSS-OVER the style, being careful of the electric fence

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Invergordon Service Base Phase 4 Development

4. Follow the high fence line around two sides of the

field, following these PATH SIGNS. The first sign is

this one at the corner of the field. The second one is

by a gate. CROSS-OVER the style, being careful of

the electric fence again.

5. Follow a grassy, SHEEP TRACK for a short distance, walking as if you are reaching the end of the

point. Before you reach the end (where there is various bits of rubbish and concrete structure),

you will see this NOBBLED POST on your right. From this point, you will get a clear lookout of the

dumping area.

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Invergordon Service Base Phase 4 Development

6. This is the look-out vista.

7. Map location of Observation Point at North Sutor.

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Invergordon Service Base Phase 4 Development

Section 12 – Page 1

Construction Environmental Management Document

Section Number 12

Section Title In-Air Acoustics

Issue 1

Issue Date 15/05/18

Author Fiona Henderson

Approved Jon Ashburner

Document History

Issue Date Reason for Change

1 15/05/18 Issued for Marine Licence Application

12 In-Air Acoustics

12.1 Introduction

The Invergordon Service Base is close to residential areas and operates 24 hours a day, 7 days

a week. The proximity to residential areas makes nuisance noise a concern, hence the

construction of Phase 4 Development must be carried out in a sympathetic manner to

minimise nuisance noise impacts. The Phase 4 Development if further from residential

receptors than previous construction phases. The construction noise modelling completed as

part of the EIA process doesn’t predict any significant effects. However, that does not negate

the need to minimise noise.

12.2 Mitigation

Timing of construction activities will be such that it will ensure noise levels detailed in Table

12.1 are not exceeded at the boundary of any noise sensitive locations. These align with

BS5228-1:2009+A1:2014 Code of Practice for Noise and Vibration Control on Construction and

Open Sites.

Table 12.1: Noise Limits at Nearest Receptors at Various Times of Day

Period Times (Hrs) Noise Limits dB LAeq,t

Daytime

07:00 – 19:00 Weekdays

07:00 – 13:00 Saturdays

Excluding Bank Holidays

65

Evenings and Weekends

19:00 – 23:00 Weekdays

13:00 – 23:00 Saturdays

07:00 – 23:00 Sundays

Bank Holidays

55

Night-time 23:00 – 07:00 50

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Section 12 – Page 2

All noise construction stage noise levels were predicted to result in noise levels of below 55dB

at the nearest noise sensitive receptors, and as such evening and weekend work is acceptable.

The majority of construction activities will be carried out between 7am and 7pm 7 days a week.

With berth dredging being carried out 24 hours a day when required.

Noise levels exceeding these limits shall only take place to deal with emergencies and in

exceptional circumstances. The Principal Contractor may make the decision to apply to the

Highland Council under Section 61 of the Control of Pollution Act 1974 (as amended) with

regard to noise levels from the construction activities.

To minimise noise levels generated, all equipment to be utilised on the site will be

appropriately maintained and switched off when not in use. Good working practices will be

employed to keep noise levels down throughout the construction process.

For each phase of the works, a review of plant requirements will be made against those

assumed in the EIA report. If the actual plant requirements are significantly different to those

predicted, a new assessment will be completed to identify any particular issues and associated

requirements for mitigation.

12.3 Monitoring

At the start of each new phase of potentially noisy work activity, noise checks will be completed

as discussed in Section 6. Initial checks will be qualitative, with the ECoW visiting noise

sensitive receptors to identify if noise that can be related to construction activities is audible

at the location. If construction noise is clearly audible, then noise monitoring will be

undertaken.

If a noise complaint is received, then noise checks as described above will also be completed.

In event of noise levels exceeding the criteria defined in Table 12.1, an investigation will be

carried out to identify whether the noise source is associated with the construction site, and if

so the reason behind the breach. This will allow additional targeted mitigation to be identified

and implemented.

All noise measurements will be taken in accordance with BS7445 Description and

Measurement of Environmental Noise. The following measurements will be recorded:

• LAeq,5 min – equivalent continuous A –weighted sound pressure level in decibels

measured over 5 minutes.

• LA10 - A-weighted sound pressure level that is exceeded for 10% of the measurement

period.

• LA90 - A-weighted sound pressure level that is exceeded for 90% of the measurement

time.

• LAmax – A weighted highest sound pressure level measured.

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Invergordon Service Base Phase 4 Development

Section 13 – Page 1

Construction Environmental Management Document

Section Number 13

Section Title Programming

Issue 1

Issue Date 15/05/18

Author Jon Ashburner

Approved Fiona Henderson

Document History

Issue Date Reason for Change

1 15/05/18 Issued for Marine Licence Application

13 Programming

13.1 Introduction This section lays out both the construction programme and the reporting programme for the

development of Phase 4.

13.2 Construction Programme The initial construction programme has now been defined and is provided in Appendix 13A.

The programme is currently high level but will be refined and updated once the Principal

Contractor has been appointed.

13.3 Reporting Programme Table 13.1 details the environmental reports expected to be produced throughout the project,

their timing, who is responsible and the regular distribution. The Project Team includes PoCF,

PoCF’s Consultant Engineers, PoCF’s Environmental Consultant, and the Principal Contractor.

It is acknowledged that Marine Scotland can request copies of any report during the project,

however they would not routinely be sent all reports.

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Section 13 – Page 2

Table 13.1: Environmental Reporting Programme

Report Timing/Frequency Responsibility Distribution

Incident / Non-conformance

Reports

In event of an incident. Project Team Project Team and if

relevant Marine

Scotland/ SEPA/SNH

Investigation Reports After and event or

incident requiring

further investigation.

ECoW Project Team and if

relevant Marine

Scotland/ SEPA/SNH

Environmental Audits Daily/Weekly/ Monthly

as per Section 5.

ECoW Project Team

Dredging Report Within 28 days of

completing dredging.

Principal

Contractor

Site Supervisor

Project Team Marine

Scotland

Waste Management Report Monthly Principal

Contractor

Project Team

In-air Noise Monitoring

Reports.

As completed Section

12.

ECoW Project Team

Impact Piling Report Weekly when Impact

Piling

ECoW/ Principal

Contractor

Project Team

Marine Scotland

Marine Mammal Observation

Reports

End of Works ECoW JNCC, Marine

Scotland Science,

SNH

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Appendix 13A – Construction Programme

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Section 14 - Page 1

Construction Environmental Management Document

Section Number 14

Section Title Schedule of Mitigation

Issue 1

Issue Date 15/05/18

Author Cornelius Pelka

Approved Fiona Henderson

Document History

Issue Date Reason for Change

1 15/05/18 Issued for Marine Licence Application

14 Schedule of Mitigation The Schedule of Mitigation is provided in Table 14.1.

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Section 14 - Page 2

Table 14.1: Draft Schedule of Mitigation

Topic Stage Aspect Mitigation/Enhancement Management Guidance EIAR

Reference

In-Air

Acoustics

Revetment

Construction

Potential Nuisance Noise. Site working hours 07:00-19:00.

White noise reversing alarms.

Equipment to be appropriately maintained.

Qualitative/Quantitative ECoW Checks.

PPG6: Working at Construction and

Demolition Sites

(https://www.sepa.org.uk/media/60125/ppg-

6-working-at-construction-and-demolition-

sites.pdf)

Chapter 6;

Section

6.6.1.

Phase 3

Rock

Armour

Removal

Potential Nuisance Noise. Site working hours 07:00-19:00.

White noise reversing alarms.

Equipment to be appropriately maintained.

PPG6: Working at Construction and

Demolition Sites

(https://www.sepa.org.uk/media/60125/ppg-

6-working-at-construction-and-demolition-

sites.pdf)

Chapter 6;

Section

6.6.1.

Quay Wall

Piling

Potential Nuisance Noise. Site working hours 07:00-19:00.

White noise reversing alarms.

Equipment to be appropriately maintained.

Qualitative/Quantitative ECoW Checks.

PPG6: Working at Construction and

Demolition Sites

(https://www.sepa.org.uk/media/60125/ppg-

6-working-at-construction-and-demolition-

sites.pdf)

Chapter 6;

Section

6.6.1.

Infilling Potential Nuisance Noise. Site working hours 07:00-19:00.

White noise reversing alarms.

Equipment to be appropriately maintained.

Qualitative/Quantitative ECoW Checks.

PPG6: Working at Construction and

Demolition Sites

(https://www.sepa.org.uk/media/60125/ppg-

6-working-at-construction-and-demolition-

sites.pdf)

Chapter 6;

Section

6.6.1.

Surfacing Potential Nuisance Noise. Site working hours 07:00-19:00.

White noise reversing alarms.

Equipment to be appropriately maintained.

Qualitative/Quantitative ECoW Checks.

PPG6: Working at Construction and

Demolition Sites

(https://www.sepa.org.uk/media/60125/ppg-

6-working-at-construction-and-demolition-

sites.pdf)

Chapter 6;

Section

6.6.1.

Operations -

Offshore

Renewables

Scenario

Potential Nuisance Noise. Noise level monitoring to be undertaken to

ensure noise remains within acceptable levels.

BSI (2014). BS 5228-1:2009+A1:2014 Code of

practice for noise and vibration control on

construction and open sites. Noise. UK:

British Standards Institute.

Chapter 6;

Section

6.6.2.

Air Quality

Revetment

Construction

Construction Dust on Invergordon Service Base Workers Implementation of a Dust Management Plan. PPG6: Working at Construction and

Demolition Sites

Chapter 8;

Section

8.6.1.1 Good material management.

Infilling Dampening of dusty materials

Surfacing Qualitative and Quantitative Monitoring. Guidance on the Assessment of dust from

demolition and construction [IAQM, 2014]

Revetment

Construction

Track out of dust Implementation of a Dust Management Plan. PPG6: Working at Construction and

Demolition Sites

Chapter 8;

Section

8.6.1.1 Covered Delivery Vehicles.

Surfacing Specific Routes.

Road Sweeping

Infilling Qualitative and Quantitative Monitoring. Guidance on the Assessment of dust from

demolition and construction

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Section 14 - Page 3

Topic Stage Aspect Mitigation/Enhancement Management Guidance EIAR

Reference

Air Quality

Construction Greenhouse Gas Emissions Material optimisation through design. Chapter 8;

Section

8.6.1.2 Local sourcing of materials where practicable.

Operations

General

Greenhouse Gas Emissions Ability to reduce lighting levels when not

required.

Chapter 8;

Section

8.6.2.1

Ornithology

Construction Disturbance due to light pollution. Directed lighting for construction area only

used.

Guidance Note: Controlling Light Pollution

and Reducing Lightning Energy

Consumption.

Chapter 11;

Section

11.6

Revetment

Construction

Accidental nest destruction. Pre-construction surveys. Chapter 11;

Section

11.6 Implementation of a Breeding Bird Protection

Plan.

Phase 3

Rock

Armour

Removal

Exclusion zones to be employed around nests if

found.

Operations

General

Disturbance due to light pollution. Lighting designed to minimise lumination out

with the development.

Ability to reduce lighting levels when not

required.

Guidance Note: Controlling Light Pollution

and Reducing Lightning Energy

Consumption

Chapter 3:

Section

3.9.4.

Operations

General

Predation risk due to predators perching on high structures. Bird deterrent spikes fitted to lighting towers. Chapter 3:

Section

3.9.4.

Marine

Mammals

Quay &

Anchor Wall

Piling

Injury/Disturbance of marine mammals due to underwater noise from piling

operations.

Piling Marine Mammal Protocol Statutory nature conservation agency

protocol for minimising the risk of injury to

marine mammals from piling noise [JNCC

2010]

Chapter 12;

Section

12.6

Revetment

Toe Dredge

Disturbance/foraging impairment/injury of marine mammals due to increased

sediment loading from dredged spoil disposal.

Dredged Spoil Disposal Marine Mammal

Protocol

Chapter 12;

Section

12.6 Berth

Dredging

Otters

Phase 3

Rock

Armour

Removal

Damage or disturbance to Holt or lay-up Pre-construction surveys. Ecology of the European Otter, Conserving

Natura 2000 Rivers Ecology Series

Chapter 13;

Section

13.6

Revetment

Construction

Visual inspection of rock armour immediately

prior to removal.

Scottish Wildlife Series: Otters and

Development, SNH 2010.

Fendering EPS Licensing if required.

Diadromous

Fish

Revetment

Toe Dredge

Disturbance/foraging impairment/disruption of migration due to increased sediment

loading from dredging and spoil disposal (Atlantic Salmon).

Dredging prohibited during the month of May. CIRIA: Coastal and Marine Environmental

Site Guide

Chapter 14:

Section

14.6.2. Berth

Dredging

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Section 14 - Page 4

Topic Stage Aspect Mitigation/Enhancement Management Guidance EIAR

Reference

Landscape

and Visual

Effects

Construction Views of construction activities. Lowering of crane arms when not in use. PPG6: Working at Construction and

Demolition Sites

Chapter 16:

Section

16.7. Removal of equipment and materials no longer

required on site.

Good housekeeping employed throughout

construction works.

Operations -

Offshore

Renewables

Scenario

Views of the offshore renewables operational site. Removal of equipment no longer required on

site.

Chapter 16:

Section

16.7. Lowering of crane arms when not in use.

Good housekeeping employed throughout.

Operations -

Cruise

Scenario

Good communications. Chapter 16;

Section

16.7.

Local

Community

and

Economy

Construction Economic Encourage local content. Chapter 17;

Section

17.6

Construction Recreation and Tourism Good communications. Chapter 17;

Section

17.6

Operation Operational effects on Recreation and Tourism. Good communications. Chapter 17;

Section

17.6

Materials

and Waste

Berth

Dredge

Dredge spoil. Reuse of dredge spoil for land reclamation

where suitable.

Chapter 18;

Section

18.5.3.3 Revetment

Toe Dredge

Construction Miscellaneous materials like wood, off-cuts of rebar metals and packaging etc. Production of an appropriate Site Waste

Management System (SWMS).

PPG6: Working at Construction and

Demolition Sites

Chapter 18;

Section

18.5.3.3 Segregation of wastes. CIRIA: Coastal and Marine Environmental

Site Guide

Construction Chemical, fuel and waste storage. Appropriate placed, secured and operated fuel

and chemical facilities.

PPG6: Working at Construction and

Demolition Sites

Chapter 18;

Section

18.5.3.2. CIRIA: Coastal and Marine Environmental

Site Guide

Refuelling only occurring in designated sites

with operatives appropriately trained.

GPP 21: Pollution Incident Response

Planning

Utilisation of bio-degradable hydraulic fluids

where practicable.

PPG 26: Safe Storage - Drums and

Intermediate Bulk Containers

GPP 21: Pollution Incident Response

Planning

COSHH assessment. Oil Storage Regulations

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Section 14 - Page 5

Topic Stage Aspect Mitigation/Enhancement Management Guidance EIAR

Reference

Materials

and Waste

Construction Storage of rock, stone and infill material. Timing delivery on 'just in time basis' as far as

practical.

CIRIA: Coastal and Marine Environmental

Site Guide

Chapter 18:

Section

18.5.3.1 Stored at an appropriate location, such that

surface water arising will not enter the sea

directly.

GPP 5: Works and Maintenance in or Near

Water

Potential utilisation of fencing to prevent use of

ground nesting birds or otters.

PPG6: Working at Construction and

Demolition Sites

Construction Litter Litter sweep prior to construction works. PPG6: Working at Construction and

Demolition Sites

Chapter 18:

Section

18.5.3.4 All working personal are to undertake site

induction with a section on waste management.

GPP 5: Works and Maintenance in or Near

Water

Reusable cutlery provided in welfare facilities. CIRIA: Coastal and Marine Environmental

Site Guide

Infilling Infill material, potential to minimise virgin material use. Investigate sources of material from dredging of

other projects.

Chapter 18:

Section18.6

Surfacing Use of cement and cement washing management Appropriate shuttering and edge protection will

be in place to contain concrete pours.

GPP 5: Works and Maintenance in or Near

Water

Chapter 18:

Section

18.3

The ECoW and Site Supervisor will inspect all

shuttering to be used during ‘over-water’ pours

of concrete such as the cope beam, to ensure it

is adequately sealed prior to the pour

commencing.

Dedicated concrete washing area 10m from

water course. Concrete allowed to settle, water if

not reused to be disposed of appropriately.

Concrete solids to be disposed of to landfill.

Traffic &

Transport

Construction Personal vehicles giving rise to parking issues. Off-road parking to be provided for

construction staff.

The Roads and Transport Guidelines for New

Development.

Chapter 19:

Section

19.5.1. Revetment

Construction

HGV movements and potential for stones to be thrown out on the public highway. FCTMP has been prepared and sets out key

principles on how the construction work will be

managed.

The Roads and Transport Guidelines for New

Development.

Surfacing Wheel inspections prior to leaving

quarry/construction site.

Planning Advice Note (PAN) 75: Planning for

Transport Construction

Operations

General

Sustainable transport access to the Service Base

for typical daily operations will be promoted

through the implementation of the FTP which

accompanies the Transport Assessment. The FTP

will support current transport polices and

government initiatives in that it will promote

and encourage walking, Cycling; and Public

transport to include Bus, taxi’s and rail.

The Roads and Transport Guidelines for New

Development.

Chapter 19:

Section

19.5.1

Operations -

Cruise

Scenario

Pedestrian movements giving rise to safety issues. Safe segregation of vehicles and non-motorised

movements within the Service Base will be in

place, especially for cruise ship visits.

Planning Advice Note (PAN) 75: Planning for

Transport

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Invergordon Service Base Phase 4 Development

Section 14 - Page 6

Topic Stage Aspect Mitigation/Enhancement Management Guidance EIAR

Reference

Water

Quality

Infilling Increased sediment in water column associated with infilling operations. Appropriate isolation of area from the Cromarty

Firth.

GPP 5: Works and Maintenance in or Near

Water

Chapter 21:

Section

21.6.1 Ongoing observations by the ECoW, with works

being stopped and improved as necessary.

PPG6: Working at Construction and

Demolition Sites

Construction Loss of containment of pollutants Spill procedure in place.

Spill kits available.

Construction personnel trained in pollution

management.

Operations

General

Loss of containment of pollutants Invergordon Service Base procedures with

regard to pollution prevention and management

to be employed.

Chapter 21:

Section

21.6.2

Navigation

Construction Navigational Risks associated with construction works. All vessels will display appropriate lights and

shapes as per the International Regulations for

Prevention of Collisions at Sea (IRPCS).

International Regulations for Prevention of

Collisions at Sea (IRPCS).

Chapter 20:

Section

20.5.1

PoCF will issue Notices to Mariners as and

Navigation Warnings as appropriate.

Prior to any construction works commencing

there will be a meeting between the

construction contractors and the Port Manager

or designate to discuss the project and

associated construction navigational issues.

The Port Manager or designate will review Risk

Assessed Method Statements (RAMS) where

navigation is a factor prior to works being

undertaken.

During construction there will be meetings at

least weekly with the construction team and the

Port Manager or designate

Information will be provided to the UK

Hydrographic Office to allow them to update

nautical charts and associated publications;

PoCF will liaise with the Northern Lighthouse

Board to agree the navigational lighting

requirements of the new Berth 6.

Operations

General

Navigational Risks associated with operations. All vessels will be expected to comply with the

International Regulations for Preventing

Collisions at Sea.

International Regulations for Prevention of

Collisions at Sea (IRPCS).

Chapter 20:

Section

20.5.2

The dredged berth pocket will be surveyed at

least once every 4 years and dredged as

required to maintain safe operational draft

depths.

The use of Anchorage No. 4 will need to be

carefully managed to prevent potential collision

issues associated with the swing area required

by larger vessels to berth alongside Berths 5 and

6.